Important information on how we use data
CLICKON Media Worldwide
1.2If you are under the age of 13, please do not use our site. Our site is not intended for children, and we do not knowingly collect or maintain the personal information of children. We will take appropriate sets to delete the personal data of any children under the age of 13.
2.1We are Click On Media Limited, a company incorporated in England and Wales. Our company number is 07950820. Our registered address is 4-8 Kilwardy Street, Ashby De La Zouch, Leicestershire LE65 2FU.
2.2If you have any queries about this Privacy Notice, or would like to contact us for any reason, please do so using the following details:
Address: 24 Greville Street, London EC1N 8SS
Email: info@clickon. co [HL3]
3.INFORMATION WE MAY COLLECT ABOUT YOU
3.1Information you give us.
3.1.1You may provide us with personal information when you:
make an enquiry, submit correspondence, provide feedback or make a complaint over the phone, by email, by post or via our site
subscribe to our newsletter and mailing lists
fill in a form, respond to surveys, participate in promotions or use any other features of the site
‘follow’, ‘like’, post to or interact with our social media accounts, including Facebook, LinkedIn, Twitter, Vimeo and YouTube, Reddit and Instagram
become our client or otherwise receive our services
work with us on projects, including as an influencer or as talent
attend meetings with us
visit our offices or studios
register to and/or attend our events
submit a CV or an application to a job vacancy
attend an interview or assessment
3.1.2Information you provide us with may include:
Identity and contact data, including titles, names, addresses, email addresses, phone numbers.
Account profile data. if you’re registering for Click On IQ account you may also provide a username, password, job title/position, language preferences and other profile data from time to time requested for delivery of the service.
Financial data. If you are entering into transactions with us, you may also provide payment details, which may include billing addresses, credit/debit card details and bank account details.
Employment, experience and background data. If you are submitting a job application, you may also provide information about your academic and work history, qualifications, skills, projects and research that you are involved in, references, proof of your entitlement to work in the UK, your national security number, your passport or other identity document details, your current level of remuneration (including benefits), and any other such similar information that you may provide to us.
Social media information. If you work with us as a social media influencer or as talent, you may provide details of your social media handles and profiles, and any publicly made posts (including photos and videos) on those social media accounts.
Survey data. From time to time we might ask if you would be willing to participate in our surveys; if you agree, we will also collect any information that you provide as part of that survey.
Special categories information: If you are submitting a job application, you may provide information about your race or ethnicity, religious beliefs, sexual orientation, health and whether or not you have any disability, and you may otherwise choose to disclose sensitive information to us.
3.2Information we collect about you
3.2.1We’ll collect the following types of information about you.
Information contained in correspondence you and us. For example, if you contact us via our site, report a problem to us by email, telephone, or post we may keep a record of your contact details and that correspondence or the nature of our correspondence.
Information related to your transactions with us. For instance, the date and time, the amounts charged and other related transaction details.
Your interaction and use of our site. This includes information such as login data, IP address, page views, searches, requests, and other actions on the site.
Technical Data. This might include your geographical location, device information (such as your hardware model, mobile network information, unique device identifiers), the data transmitted by your browser (such as your IP address, date and type of the request, content of the request regarding the specific site, time zone settings, access status/HTTP status code, volume of data transmitted, browser type and version, language settings, time zone settings referral source, length of visit to the site, date and time of the request, operating system and interface) number of page views, the search queries you make on the site and similar information. This information may be collected by a third-party site analytics service provider on our behalf and/or may be collected using cookies or similar technologies. For more information on cookies please read the Cookies section below.
3.3Information we receive from third parties
3.3.1In certain circumstances, we may receive personal information about you from third parties like:
·Social media profile information. If you work with us as a social media influencer and have provided us with details of your social media profiles and handles, we will collect information about your publicly made posts (including photos and videos) as well as your affiliation with relevant brands.
·Social media service providers. If you interact with us via social media, we may collect information about those interactions from social media service providers including Facebook, LinkedIn, Twitter, Vimeo, YouTube, Reddit and Instagram.
·Other social media users. For example information that is posted or uploaded by other users (e.g. reviews), information relating our service and/or correspondence between site appearing on our social media profile pages, and information posted by other social media users on our influencer pages.
·Fraud detection agencies. Including demographic data or fraud detection information from third party service providers and/or partners.
·Employers, recruitment agencies and referees. If you are a job applicant we may contact your recruiter, current and former employers and/or referees, who may be based inside or outside the EU, to provide information about you and your application.
·Service providers. Including our site developer, IT support provider, payment services provider, marketing service providers, advertising services provider and our lead and sales generation service providers[H&L4] .
·Publicly available sources. Such as Companies House, LinkedIn, public sites, and social media accounts, for instance to carry out identity and compliance checks.
·Our clients. For instance, information about employees and staff members of our clients, their subcontractors and others they work with, and referrals for work.
People we work with in order to provide our clients with the services they have requested. Including media buying agencies, talent agencies, directors, producers, software providers and other intermediaries. [H&L5]
·We might also receive information about you from third parties if you have indicated to such third party that you would like to hear from us.
3.4Special categories of data
3.4.1“Special categories” of particularly sensitive personal information require higher levels of protection. We need to have further justification for collecting, storing and using this type of personal information. We have in place appropriate safeguards which we are required by law to maintain when processing such data. We process special categories of personal information where we are required to do so by law, or where it is needed for reasons of substantial public interest, e.g. equal opportunities monitoring.
4.HOW WE USE INFORMATION ABOUT YOU
4.1We will use your information for the purposes listed below either on the basis of:
4.1.1performance of your contract with us and the provision of our services to you;
4.1.2your consent (where we request it);
4.1.3where we need to comply with a legal or regulatory obligation; or
4.1.4our legitimate interests or those of a third party. Where we refer to using your information on the basis of our “legitimate interests”, we mean our legitimate business interests in conducting and managing our business and our relationship with you.
4.2We use your information for the following purposes:
4.2.1To provide you with access to our site and Content, in a manner convenient and optimal and with personalised Content relevant to you including sharing your information with our site hosts and developers
4.2.2To provide you with the services that you may have requested from us.
4.2.3To register and maintain your Click On IQ account, when you become a client, in certain circumstances, we will use the details provided by you to create and maintain an account with us.
4.2.4To process and facilitate transactions and payments, and to collect and recover money owed to us.
4.2.6To conduct business with you or your employer, and manage and facilitate our business relationship with you and/or your employer.
4.2.7To enable you to take part in prize draws, competitions and surveys.
4.2.8For recruitment, including to process any applications for influencer marketing, talent and other that you submit to us, whether directly or via an agent or recruiter including sharing this with our third party recruitment agency.
4.2.9For marketing, including to promote the work we have done for our clients, including content we have created on our sites and in other media[H&L6] , to keep in contact with you about our news, events, new site features, products or services that we believe may interest you, provided that we have the requisite permission to do so, and sharing your information with our marketing services providers.
4.2.10For advertising, including to deliver relevant site content and online advertisements to you (including via social media) and measure or understand the effectiveness of the advertising we serve to you.
4.2.11To interact on social media, including on Facebook, LinkedIn, Twitter, YouTube, Vimeo, Reddit and Instagram, for example, responding to comments and messages, posting, ‘retweeting’ and ‘liking’ posts.
4.2.12For analytics, including using data analytics to improve our site, products/services, marketing, advertising, customer relationships and experiences.
4.2.13For research, including carrying out aggregated and anonymised research about general engagement with our site.
4.2.14For fraud and unlawful activity detection, and to protect, investigate, and deter against fraudulent, unauthorised, or illegal activity, including identity fraud.
4.2.15For compliance with policies, procedures and laws, and to enforce our legal rights, or to protect the rights, property or safety of our staff and share your information with our technical and legal advisors.
5.WHO WE MIGHT SHARE YOUR INFORMATION WITH
5.1In connection with the purposes and on the lawful grounds described above and in addition to the recipients of your information as described above, we will share your personal information when relevant with third parties such as:
5.1.1Our clients, for example, providing them with details of talent and social media influencers that may be suitable for their campaigns, providing clients with media buying services, creating content for campaigns and developing apps and software.
5.1.2People we work with in order to provide our clients with the services they have requested, for example media buying agencies, talent agencies, directors, producers, software providers and other intermediaries[H&L7] .
5.1.3Our service providers, with whom we work with to deliver our business, who are acting as processors and provide us with:
·site development and hosting services based in the UK and the USA;
·IT, system administration and security services based in the UK and the USA;
·advertising and analytics services (including, but not limited to Google AdWords, Google Analytics, Facebook Business and Facebook Analytics);
marketing and lead generation services based in the UK and USA;
·maps services (including Google Maps API);
·social media account services including Facebook, Google+, Twitter, LinkedIn, YouTube, Vimeo, Reddit and Instagram;
·payment services based in the UK and the USA;
·identity verification, fraud prevention and detection services based in the UK and USA;
·banking services based in the UK and USA;
·legal, accountancy, auditing and insurance services and other professional advisers based in the UK and USA;
·recruitment service providers based in the UK and USA;
5.1.4Regulators and governmental bodies: HM Revenue & Customs, regulators, governmental bodies and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances;
5.1.5Marketing parties: any selected third party that you consent to our sharing your information with for marketing purposes;
5.1.6Prospective sellers and buyers of our business: any prospective seller or buyer of such business or assets, only in the event that we decide to sell or buy any business or assets; and
5.1.7Other third parties (including professional advisers): any other third parties (including legal or other advisors, regulatory authorities, courts, law enforcement agencies and government agencies) where necessary to enable us to enforce our legal rights, or to protect the rights, property or safety of our employees or where such disclosure may be permitted or required by law.
5.2We require third party processors of your personal information to maintain appropriate security to protect your information from unauthorised access or processing.
6.2If you do not wish for cookies to be installed on your device, you can change the settings on your browser or device to reject cookies. For more information about how to reject cookies using your internet browser settings please consult the “Help” section of your internet browser (or alternatively visit http://www.aboutcookies.org). Please note that, if you do set your Internet browser to reject cookies, you may not be able to access all of the functions of the site and your experience may be less satisfying.
6.3The names of the cookies that we operate on our site and the purposes for which these cookies are used are as follows:[HL 8]
7.HOW WE LOOK AFTER YOUR INFORMATION AND HOW LONG WE KEEP IT FOR
7.1We operate a policy of “privacy by design” by looking for opportunities to minimise the amount of personal information we hold about you. We use appropriate technological and operational security measures to protect your information against any unauthorised access or unlawful use, such as:
7.1.1ensuring the physical security of our offices, studios or other sites;
7.1.2ensuring the physical and digital security of our equipment and devices by using appropriate password protection and two-factor authentication;
7.1.3maintaining a data protection policy for, and delivering data protection training to, our employees; and
7.1.4limiting access to your personal information to those in our company who need to use it in the course of their work.
7.2We will retain your information for as long as is necessary to provide you with the services that you have requested from us or for as long as we reasonably require to retain the information for our lawful business purposes, such as for the purposes of exercising our legal rights or where we are permitted to do. We operate a data retention policy and look to find ways to reduce the amount of information we hold about you and the length of time that we need to keep it.
8.INTERNATIONAL TRANSFERS OF YOUR INFORMATION
8.1Our company is located in the UK.
8.2Many of the third parties we work with are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
8.3Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following transfer solutions are implemented:
8.3.1We will transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries;
8.3.2Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries; and
8.3.3Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.
8.4Please contact us using the contact details at the top of this Privacy Notice if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
9.YOUR RIGHTS TO THE INFORMATION WE HOLD ABOUT YOU
9.1You have certain rights in respect of the information that we hold about you, including:
9.1.1the right to be informed of the ways in which we use your information, as we seek to do in this Privacy Notice;
9.1.2the right to ask us not to process your personal data for marketing purposes;
9.1.3the right to request access to the information that we hold about you;
9.1.4the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect;
9.1.5the right to withdraw your consent for our use of your information in reliance of your consent (refer to section 2 above to see when we are relying on your consent), which you can do by contacting us using any of the details at the top of this Privacy Notice;
9.1.6the right to object to our using your information on the basis of our legitimate interests (refer to section 2 above to see when we are relying on our legitimate interests) (or those of a third party)) and there is something about your particular situation which makes you want to object to processing on this ground;
9.1.7the right to receive a copy of any information we hold about you (or request that we transfer this to another service provider) in a structured, commonly-used, machine readable format, in certain circumstances;
9.1.8in certain circumstances, the right to ask us to limit or cease processing or erase information we hold about you; and
9.1.9the right to lodge a complaint about us to the UK Information Commissioner’s Office (https://ico.org.uk/) as well as a right to lodge a complaint with the relevant authority in your country of work or residence.
9.2Please note that we may need to retain certain information for our own record-keeping and research purposes. We may also need to send you service-related communications relating to your App user account even when you have requested not to receive marketing communications.
9.3How to exercise your rights
9.3.1You may exercise your rights above by contacting us using the details in paragraph 2 of this Privacy Notice, or in the case of preventing processing for marketing activities also by checking certain boxes on forms that we use to collect your data to tell us that you don’t want to be involved in marketing or by updating your marketing preferences via your account with us.
9.3.2You may contact us via the details at the top of this Privacy Notice if you wish to action any of these additional rights and we will comply with your requests unless we have a lawful reason not to do so.
9.4What we need from you to process your requests
9.4.1We may need to request specific information from you to help us confirm your identity and to enable you 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.
9.4.2You 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. We will 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.
10.SHARING DATA DIRECTLY WITH THIRD PARTIES
10.1You might end up providing personal information directly to third parties as a consequence of your interactions with our site and other services offered by us. For example, you may attend an event hosted by us where you communicate personal information directly with other attendees. We are not responsible for how such third parties use personal data provided by you.
10.2Please be responsible with personal information of others. We are not responsible for your misuse of personal information, or for the direct relationship between you and others when takes place outside of the site or our services.
The site may include links to third-party sites, 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 sites and are not responsible for their privacy statements. When you leave our site, we encourage you to read the privacy notice of every site you visit.
12.CHANGES TO THIS PRIVACY NOTICE AND YOUR DUTY TO INFORM US OF CHANGES
12.1We may make changes to this Privacy Notice from time to time. We will post any changes to our site, or notify you of any material changes by e-mail.
12.2It 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 by updating your profile account information or contacting us via the contact details at the top of this Privacy Notice.
This Privacy Notice was updated on January 2020.