This policy applies to you and us The Digital Unit Ltd of W8a Knoll Business Centre, 325-327 Old Shoreham Road, Hove, United Kingdom, BN3 7GS, (hereinafter “the digital unit” or “TDU” or “we” or “us”) regardless of the country in which you reside or are located.
This policy describes our privacy practices in plain language, keeping legal and technical jargon to a minimum, to ensure that you understand what information we collect, why we collect it, how it is used and what choices you have about your information.
For any enquires regarding privacy please email our data officer at firstname.lastname@example.org
What is personal data?
Personal Data is information by which you can be directly or indirectly identified (“Personal Data”). This generally includes information such as your name, address, email address and telephone number; however, it may also include other information such as your IP address or preferences and interests.
What is processing?
“Processing” means any operation or set of operations which is performed upon personal data, whether or not by automatic means. The term is broad and covers virtually any handling of data.
What is the applicable data protection law?
As a UK based Company we are bound to follow the UK’s Data Protection Act (“DPA”). Since we are however a company that operates globally we have also adopted the principles set out in the EU’s General Data Protection Regulation (“GDPR”). Given the similarity of both provisions no conflict should arise, but if it does we will follow the most stringent provision in order to ensure the highest data protection standard available.
Who is the supervisory authority?
The Information Commissioner’s Office (ICO) provides advice and information for individuals about protecting personal information. They also enforce federal privacy laws and are the for us relevant data protection authority. You can find the ICO’s contact details on their website at www.ico.org.uk.
What are the legal bases of processing personal data?
The legal bases for processing are listed below and at least one of these must apply whenever we process personal data:
- Consent: the individual has given clear consent to process personal data for a specific purpose.
- Contract: the processing is necessary for a contract or because you have asked us to take specific steps before entering into a contract.
- Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).
- Vital interests: the processing is necessary to protect someone’s life.
- Public task: the processing is necessary for us to perform a task in the public interest or for official functions, and the task or function has a clear basis in law.
- Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party, unless there is a good reason to protect your personal data which overrides those legitimate interests
What are your rights?
You have the following rights with respect to us processing your personal data:
- Right of access
You have the right to obtain information about whether and which of your personal data is processed by us. In this case, we will also inform you about:
- the purpose of processing;
- the categories of data;
- the recipients of your personal data;
- the planned storage period or the criteria for the planned storage period;
- Your further rights;
Unless we have been provided with your personal data by you: Any available information about its origin if available: the existence of automated decision-making and information about the logic involved, the scope and the intended effects of the processing.
- Right to rectification
You have a right to rectification and/or completion if your personal data processed by us is inaccurate or incomplete.
- Right to restriction of processing
You have a right to restriction of processing, provided that
- we verify the accuracy of your personal data processed by us;
- the processing of your personal data is unlawful;
- you need your personal data processed by us for legal prosecution after the purpose has ceased to exist;
- you have objected to the processing of your personal data and we are reviewing this objection.
- Right to erasure
You have a right to erasure if
- we no longer need your personal data for its original purpose;
- You withdraw your consent and there is no further legal basis for processing your personal data;
- you object to the processing of your personal data and – unless it is direct marketing – there are no overriding reasons for further processing;
- the processing of your personal data is unlawful;
- the erasure of your personal data is required by law;
- your personal data was collected as a minor for information society services.
- Right to information
If you have exercised your right to rectification, erasure or restriction of processing, we will inform all recipients of your personal data, of this rectification, erasure of data or restriction of processing.
- Right to data portability
You have a right to receive your personal data processed by us on the basis of consent or for the performance of a contract in a structured, common and machine-readable format and to transfer it to another controller. If technically feasible, you have the right to have us transfer this data directly to another controller.
Right to object
You have the right to object to the processing of your personal data in case of special reasons. In this case, we will no longer process your personal data unless we can demonstrate compelling legitimate grounds for the processing.
- In case of processing of your personal data for direct marketing purposes, you have the right to object at any time.
- Right of withdrawal
You have the right to revoke any consent given to us at any time. The revocation of consent does not affect the lawfulness of the processing carried out on the basis of the consent until the revocation.
- Right to complain to a supervisory authority
Without prejudice to any other administrative or judicial remedy, you have the right to lodge a complaint with the competent supervisory authority if you believe that the processing of your personal data by us violates the law.
Provision of the website and creation of log files
The legal basis for the processing of your personal data in the context of the provision of the website and the creation of log files is our legitimate interest. The temporary storage of your personal data by us is necessary to enable delivery of the website to your computer or device. For this purpose, your personal data must be stored for the duration of the session. The storage of your personal data in log files is done to ensure the functionality of the website. In addition, we use your personal data to optimise the website and to ensure the security of our information technology systems. Your personal data is not processed in any other way.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the collection of your personal data for the provision of the website, this is given as soon as you have left the website. In the case of storage of your personal data in log files, these are deleted after 7 days at the latest. If the data is stored beyond this period, your personal data will be anonymised so that it can no longer be assigned. The collection of your personal data for the provision of the website and the storage of your personal data in log files is absolutely necessary for the operation of the website. Consequently, there is no possibility for you to object.
Use of technically necessary cookies
Influencer Account registration
The legal basis for the processing of your personal data in the context of influencer account registration is the performance of a contract. Your registration enables in particular the conclusion of contracts as well as the maintenance of our business relationship. We collect data when you create or update your account and this may
include your name, email, phone number, login name and password, payment, marketing or banking information. The processing of your personal data within the scope of registration is therefore necessary for the fulfilment of a contract or the implementation of pre-contractual measures as well as the successful maintenance of our relationship.
If you sign up to join our influencer program, we collect some information to allow you to join our network such data may include email, personal information, payment details and social network information. The information helps us and our merchants to evaluate influencer background and potential, along with process specific activities and contact details if needed. This is done in our legitimate interests i.e. interest in the economic operation of our services, and was designed to provide a medium of financial support by means of which advertising fees can be earned through the placement of advertisements and links to our influencer network.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. This is the case at the latest in the event of the termination of your customer account. You have the option to cancel your customer account registration at any time. In this case, your personal data will be deleted unless legal retention periods prevent deletion.
Processing of data
We collect, process and use personal data only to the extent that it is necessary for the establishment, content or amendment of the legal relationship. This is done on the basis of a contract or pre-contractual measures. We collect, process and use personal data about the use of our Internet pages only insofar as this is necessary to enable the user to use the service or to bill the user.
The collected customer data is deleted after completion of the order or termination of the business relationship. Legal retention periods remain unaffected.
Commercial and business services
We process data of our contractual and business partners, e.g. influencers and interested parties in the context of contractual and comparable legal relationships as well as related measures and in the context of communication. We process this data to fulfil our contractual obligations, to secure our rights and for the purposes of the administrative tasks associated with this information as well as for business organisation.
We only disclose the data of the contractual partners to third parties within the scope of the applicable law to the extent that this is necessary for the aforementioned purposes or for the fulfilment of legal obligations or with the consent of the contractual partners (e.g. to participating telecommunications, transport and other auxiliary services as well as subcontractors, banks, tax and legal advisors, payment service providers or tax authorities).
We inform the contractual partners which data is required for the aforementioned purposes before or in the course of data collection, e.g. in online forms, by means of special labelling (e.g. colours) or symbols (e.g. asterisks or similar), or in person.
Unless otherwise specified the purposes of processing are Contractual performance and service, contact requests and communication, office and organisational procedures, administration and response to requests, visit action evaluation, interest-based and behavioural marketing, profiling (creating profiles of users). And, the
Legal bases are Contractual performance and pre-contractual enquiries, Legal obligation, and our Legitimate interests.
We process the data of our customers within the scope of our contractual services, which include conceptual and strategic marketing, campaign planning, software and design development/consulting or maintenance, implementation of marketing campaigns and processes/handling, administration, data analysis/consulting services and training services. In doing so, we process inventory data, contact data, content data, contract data, payment data, usage data and metadata (e.g., in the context of evaluating and measuring the success of marketing measures). As a matter of principle, we do not process special categories of personal data, unless these are components of commissioned processing. Data subjects include our customers, prospective customers as well as their customers, users, website visitors or employees as well as third parties. The purpose of the processing is the provision of contractual services, billing and our customer service. The legal basis for the processing results from contractual services, analysis, statistics, optimisation, security measures. We process data that is necessary for the justification and fulfilment of contractual services and point out the necessity of their disclosure. We delete the data after the expiry of statutory warranty and comparable obligations.
Administration, financial accounting, office organisation, contact management
We process data within the scope of administrative tasks as well as organisation of our business, financial accounting and compliance with legal obligations, such as archiving. In doing so, we process the same data that we process in the course of providing our contractual services. The processing bases are a legal obligation and our legitimate interest. Customers, interested parties, business partners and website visitors are affected by the processing. The purpose and our interest in the processing lies in the administration, financial accounting, office organisation, archiving of data, i.e. tasks that serve the maintenance of our business activities, performance of our tasks and provision of our services. The deletion of data with regard to contractual services and contractual communication corresponds to the information mentioned in these processing activities.
In this context, we disclose or transmit data to the tax authorities, consultants such as tax advisors or auditors as well as other fee offices and payment service providers.
Furthermore, we store information on suppliers, organisers and other business partners on the basis of our business interests, e.g. for the purpose of contacting them at a later date. This data, most of which is company-related, is stored permanently.
When contacting us (e.g. via contact form, e-mail, telephone or social media), the user’s details are processed for the purpose of handling the contact request and its processing. The user’s details may be stored in a customer relationship management system (“CRM system”) or comparable enquiry organisation.
We delete the enquiries if they are no longer necessary. We review the necessity every two years; furthermore, the legal archiving obligations apply.
Cooperation with processors and third parties
If, in the course of our processing, we disclose data to other persons and companies transmit it to them or otherwise grant them access to the data, this will only be done on the basis of a legal permission, you have consented, a legal obligation provides for this or on the basis of our legitimate interests (e.g. when using agents, web hosts, etc.).
The legal basis for the processing of your personal data in the context of direct marketing measures is either your consent or our legitimate interest in marketing and
promoting our courses and services. The purpose of processing your personal data in the context of direct marketing measures is to send information, offers and, if applicable, to promote sales.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected; this is the case in particular upon receipt of the revocation or objection. You can revoke your consent at any time for the future or object to the processing of your personal data in the context of direct marketing measures at any time for the future.
- Right of access
- Monetise Media Ltd
- Monetise Media Client list
When you send a data subject access request
The legal basis for the processing of your personal data in the context of handling your data subject access request is our legal obligation and the legal basis for the subsequent documentation of the data subject access request is both our legitimate interest and our legal obligation. The purpose of processing your personal data in the context of processing data when you send a data subject access request is to respond to your request. The subsequent documentation of the data subject access request serves to fulfil the legally required accountability.
Your personal data will be deleted as soon as they are no longer required to achieve the purpose for which they were collected. In the case of the processing of a data subject access request, this is three years after the end of the respective process. You have the possibility at any time to object to the processing of your personal data in the context of the processing of a data subject access request for the future. In this case, however, we will not be able to further process your request. The documentation of the legally compliant processing of the respective data subject access request is mandatory. Consequently, there is no possibility for you to object.
Legal defence and enforcement of our rights
The legal basis for the processing of your personal data in the context of legal defence and enforcement of our rights is our legitimate interest. The purpose of processing your personal data in the context of legal defence and enforcement of our rights is the defence against unjustified claims and the legal enforcement and assertion of claims and rights.
Your personal data will be deleted as soon as they are no longer necessary to achieve the purpose for which they were collected. The processing of your personal data in the context of legal defence and enforcement is mandatory for legal defence and enforcement of our rights. Consequently, there is no possibility for you to object.
SSL or TLS encryption
For security reasons and to protect the transmission of confidential content, such as orders or enquiries that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Our website is not intended for children and we do not knowingly collect data relating to children. If you become aware that your Child has provided us with Personal Data, without parental consent, please contact us and we take the necessary steps to remove that information from our server.
It is important that the data we hold about you is accurate and current, therefore please keep us informed of any changes to your personal data.
For security reasons and to protect the transmission of content, that you send to us, this site uses SSL or TLS encryption. You can recognise an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.
Obligation to provide personal data
You are not obliged to provide us with personal data. However, depending on the individual case, the provision of certain personal data may be necessary for the provision of the above services. If you do not provide us with this personal data, we may not be able to provide the service.
Do Not Sell My Personal Information
We do not sell information that directly identifies you, like your name, address or phone records.
Content Delivery Network
For the purpose of a shorter loading time, we use a so-called Content Delivery Network (“CDN”) for some offers. With this service, content, e.g. large media files, are delivered via regionally distributed servers of external CDN service providers. Therefore, access data is processed on the servers of the service providers. Our service providers work for us within the framework of order processing. If you have any questions about our service providers and the basis of our cooperation with them, please contact us.
Changes and Questions