Privacy policy

InterMedia Brand Marketing Limited (“we“) respect your privacy and are committed to protecting your personal data.

This privacy policy will inform you as to how we look after your personal data when you visit our website at site www.inter-media.co.uk (“our site”)
(regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

This privacy policy aims to give you information on how we collect and process your personal data through your use of our site, including any data
you may provide through our site when you sign up to our eNewsletter or contact us through our site.

This website is not intended for children and we do not knowingly collect data relating to children.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice 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 policy supplements the other notices and is not intended to override them.

Your acceptance of this privacy policy is deemed to occur upon your first use of our site. If you do not accept and agree with this privacy policy,
you must stop using our site immediately.

PERSONAL DATA

You may be asked to provide personal data whilst you are in contact with us. Personal data is information that can be used to identify or contact
you. You do not have to provide the personal data that we request, however, if you choose not to, we may not be able to provide you with the
services that you have requested.

If we combine personal data with non-personal data, the combined information will be treated as personal data for as long as it remains combined.
Personal data does not include data where the identity has been removed (anonymous data).

CONTROLLER

For the purpose of the retained EU law version of the General Data Protection Regulations ((EU) 2016/679) and the Data Protection Act 2018 (“Data Protection Legislation”) the data controller is Intermedia Brand Marketing Limited a company registered in England and Wales with company registration number 07256268 whose registered office is at North Quay House, Sutton Harbour, Plymouth, Devon, United Kingdom, PL4 0RA. Our main trading address is at Unit 6, The Enterprise Centre, Kelvin Lane, Manor Royal, Crawley, West Sussex, RH10 9PE. Our Data Protection Registration Number is Z3511096.

InterMedia Brand Marketing Limited is part of a group of companies. This privacy policy is issued on behalf of the InterMedia Group so when we
mention “InterMedia“, “we“, “us” or “our” in this privacy policy, we are referring to the relevant company in the InterMedia Group responsible for
processing your data. InterMedia Brand Marketing Limited is the controller and responsible for this site.

INFORMATION WE MAY COLLECT FROM YOU AND HOW WE USE IT

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes your first name, last name, title, date of birth and gender. The identity data may be may be processed for the purpose of
providing services to you, managing our relationship with you (including notifying you about changes to our privacy policy), enabling you to apply
for employment vacancies, to administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data). The legal basis for this processing is the performance of a contract and/or taking steps, at your request,
to enter into such a contract and our legitimate interests (namely to keep our records updated, to study how our site is used, for the running of
our business, provision of administration and IT services and network security).

Contact Data includes your postal address, email address and telephone number. The contact data may be processed for the purpose of providing
services to you, managing our relationship with you (including notifying you about changes to our privacy policy), enabling you to apply for
employment vacancies, to administer and protect our business and site (including troubleshooting, data analysis, testing, system maintenance,
support, reporting and hosting of data). The legal basis for this processing is the performance of a contract and/or taking steps, at your request,
to enter into such a contract and our legitimate interests (keep our records updated, to study how our site is used, for the running of our business,
provision of administration and IT services and network security).

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in
types and versions, operating system and platform and other technology on the devices you use to access this site. The technical data may be
processed for the purpose of administering and protecting our business and site (including troubleshooting, data analysis, testing, system
maintenance, support, reporting and hosting of data) and to deliver relevant website content to you. The legal basis for this processing is our
legitimate interests (namely to grow our business and to inform our marketing strategy).

Profile Data includes your email, your interests, preferences and feedback. The profile data may be processed for the purpose of managing our
relationship with you (including notifying you about changes to our privacy policy). The legal basis for this processing is the performance of a
contract and our legitimate interests (namely to keep our records updated, to study how our site is used and to grow our business and to inform
our marketing strategy).

Usage Data includes information about how you use our site. This usage data may be processed for the purposes of delivering relevant website
content to you, to use data analytics to improve our website, marketing, customer relationships and experiences. The legal basis for this
processing is the performance of a contract and our legitimate interests (namely to study how our site is used and to grow our business and to
keep our site updated and relevant).

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication
preferences. The marketing and communications data may be processed for the purposes of sending you newsletters. The legal basis for this
processing is consent.

In addition to the specific purposes for which we may process your personal data set above, we may also process any of your personal data where
such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital
interests of another natural person.

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 oences. If you provide Special Categories of Personal Data through our site as part
of a recruitment campaign and are subsequently employed by us, this type of personal data will be processed in accordance with our sta
handbook and employment contracts.

We may also provide you with information about oers and services that are similar to those that you have already received or we feel may
interest you. If you:

have already concluded a contract with us (for example, you have already entered into a contract with us for the supply of services), we will only
contact you by electronic means (email or text) with information about oers and services similar to those which were the subject of a previous
contract. If you do not want to be on our mailing list, you can opt out at any time by contacting us or unsubscribing by using the links provided in
our electronic communications and at the point of providing your details.

are a potential new customer (for example, you are enquiring about our services), we will contact you by electronic means only if you have
provided your explicit consent to this. If you are happy for us to use your personal data in this way, please tick the relevant box situated on the
website page on which we collect your details. Again, if you do not want us to use your data in this way, you can opt out at any time by contacting
us or unsubscribing by using the links provided in our electronic communications.

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 and Contact Data by filling in forms or by corresponding with us by post, phone, email or
otherwise. This includes personal data you provide when you:

• sign up for the eNewsletter;
• send CVs and recruitment related information to us via our site;
• contact us through our site;
• request marketing to be sent to you; or
• give us some feedback.
• Automated technologies or interactions. As you interact with our site, we may automatically collect Technical Data about your equipment,
  browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies.
• Third parties or publicly available sources. We may receive personal data about you from various third parties which include:
• Technical Data from analytics providers (such as Google) based outside the UK and search engine providers based outside the UK;
• Contact Data from providers of technical services; and
• Identity and Contact Data from publicly available sources such as Companies House and the Electoral Register based inside the UK.

INTERNATIONAL TRANSFERS

Some of the third parties which we work closely with are based outside of the UK so their processing of your personal data will involve a transfer of data outside of the UK.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

• we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; and
• where we use certain service providers, we may use specific contracts approved for use in the UK which give personal data the same protection it has in the UK.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal
data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your
information, we will use strict procedures and security features to try to prevent unauthorised access.

COOKIES

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse
cookies, please note that some parts of this site may become inaccessible or not function properly. For more information about the cookies we
use, please see our Cookie Policy

CHANGE OF PURPOSE

We will ask for your consent before using personal data for a purpose other than those set out in this privacy policy, unless we reasonably consider
that we need to use it for another reason and that reason is compatible with the original purpose. If you would like further information on purpose
compatibility, please contact us.

DISCLOSURE OF YOUR INFORMATION

You agree that we may disclose your information (including personal data) to the following categories of third parties:

• any member of the InterMedia Group, which means our subsidiaries as defined in section 1159 of the UK Companies Act 2006.
• suppliers, agents and sub-contractors for the performance of any contract we enter into with them or you;
• professional advisers including lawyers, accountants and insurers;
• analytics and search engine providers that assist us in the improvement and optimisation of our site;
• data storage providers, in connection with cloud storage and hosting services; and
• third-party auditing organisation (Audit Bureau of Circulations Ltd (ABC)) so they can verify aggregated statistics about circulation and usage
  of our products or review our policies, processes and procedures for compliance with relevant standards. You can view their privacy policy by
  following this abc.org.uk/privacy-policy. Please note that, due to the high degree of skill and autonomy used by ABC in performing their
  auditing services, they are likely to be acting as a data controller in common with InterMedia.

Your personal data will not be shared with third parties for third party marketing purposes unless you have provided your express consent.

We may disclose your personal data to third parties:

• where we have your consent to do so;
• to provide and/or improve our services;
• in the event that we sell or buy any business or assets, in which case we may disclose your personal data to the prospective seller or buyer of
  such business or assets;

if InterMedia Brand Marketing Limited or substantially all of our assets are acquired by a third party, in which case personal data held by us about
you will be one of the transferred assets; and

if we are under a duty to disclose or share your personal data in order to comply with any legal obligation, or to protect the rights of InterMedia
Brand Marketing Limited, our customers, publishers or others. This includes exchanging information with other companies and organisations for
the purposes of fraud protection and credit risk reduction.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. Subject to ABC who perform
third party audits, 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.

YOUR RIGHTS

Under Data Protection Legislation, in certain circumstances you have the following rights in relation to your personal data:

• Right to access. You have the right to request access to information held about you. We will provide you with a copy of your personal data
  held by us free of charge (providing your request is not excessive or for multiple copies, in which case we may charge a reasonable fee to cover
  our costs) and certain information about the processing of your personal data and the source of such data (if not directly collected from you
  by us). You also have the right to request that your personal data is transferred to a third party.
• Right to object to data processing. You may withdraw your consent to the processing of your personal data at any time by contacting us or
  ticking a box to opt out of receiving marketing materials. Upon receipt of your notification, we shall promptly stop any processing of your
  personal data and (if requested by you) erase such information if we are not required to retain it for legitimate business or legal purposes.
• Right to restrict processing. You may ask us to suspend the processing of your personal data in the following circumstances:
  - if you do not think your personal data is accurate;
  - where we are found to be processing unlawfully but you do not want us to erase your personal data;
  - where you need us to continue holding your personal data to establish, exercise or defend legal claims; or
  - you have objected to our use of your personal data but we need to verify whether we have overriding legitimate grounds to use it.
• Right of rectification and right of erasure. You have the right to request that we correct or erase any inaccuracies in your personal data if
  such information would be incomplete, inaccurate or processed unlawfully.

Where we are relying on consent to process your personal data, you may withdraw consent at any time. However, this will not aect 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
services to you. We will advise you if this is the case at the time you withdraw your consent.

You can also exercise these rights at any time by contacting us at getintouch@inter-media.co.uk. We may reject requests that are unreasonable or
require disproportionate eort (for example, such a request would result in a fundamental change to our existing practice) or risk the privacy of
others.

Our site may, from time to time, contain links to and from third party websites. If you follow a link to any of these websites, please note that these
websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies
before you submit any personal data to these websites.

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.

Personal data retention

We may retain information about you, including personal data, for the period necessary to fulfil the purposes for which it was first collected unless
a longer retention period is required or permitted by law. In determining data retention periods, we take into consideration contractual obligations,
legal obligations and the expectation and requirements of our customers. When personal data is no longer needed, we will securely delete or
destroy it.

In some circumstances we may 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.

Changes to our privacy policy and your duty to inform us of changes

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by email. Please
check back frequently to see any updates or changes to our privacy policy.

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.

Contacting us

If you have any questions, comments or requests regarding this privacy policy or data processing or you would like to make a complaint, please
contact us via email at dataprotectionoicer@inter-media.co.uk by telephone on 01293 312001 and by post to Unit 6, The Enterprise Centre, Kelvin
Lane, Manor Royal, Crawley, West Sussex, RH10 9PE.

If you have any cause for complaint about our use of your personal data, please contact us using the details provided above and we will do our best to solve the problem for you. If we are unable to help, you also have the right to lodge a complaint with the Information Commissioner’s Office (www.ico.org.uk).

Last updated: 2021