If at any point in time TW Media decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, users shall be promptly notified by email. Users at that time shall have the option as to whether or not to permit the use of their information in this separate manner.
This Policy covers your access to our Services and to this Site which is not intended for access and use by persons under the age of 16. Anyone under the age of 16 must seek and obtain the permission of their parent, guardian or legally approved appropriate adult to use this website. TW Media does not intentionally collect or use Personal Data from users that we have reason to believe are under the age of 16 without verifiable parental/guardianship or appropriate adult consent. If it is determined that such information has been inadvertently collected on anyone under the age of 16, we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database.
The type of Personal Data (defined below) and Other Data (also defined below and more particularly in Section 7 on Collection and Use of Other Data) we collect depends on how you are specifically interacting with this Site and using our Services. When you visit this Site, make a purchase or attempt to make a purchase, we collect various types of information:
1. “Personal Data” or “Order Information”: Information that has been voluntarily provided by you that identifies you or can be used to identify or contact you which may include your name, address, phone number, email address, usage data, billing, shipping and/or credit card information, etc., which may be used when you request information, purchase products and/or services and to deliver the services you have requested;
2. Anonymous demographic information, such as age, gender, household income, political affiliation, race, and religion;
3. Information about your device (unique device identifiers) the type of web browser you are using, IP address, time zone, or type of operating system to assist us in providing and maintaining superior quality service; and
4. “Device Information”: automatically-collected information when visiting our website, which may include cookies, third party tracking technologies, server logs, individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site;
Further explanation and clarification of Personal Data is provided below:
a) Account Registration: The registration process requests that you provide your name, email address, address, phone number, company affiliation if any, and other similar information. This information must be stored on this Site, and is accessible to anyone with whom you share your username and password. For this reason, please safeguard your username and password carefully and do not disclose it to any other person.
b) Voluntary Disclosure: Personal Data voluntarily provided by you, includes emails to this Site, online forms, order and registration forms, surveys, promotion participation, phone calls and online chats with our customer service and through other means.
d) Log data: This includes network and connection information (including Internet Service Provider (ISP) and Internet Protocol (IP) addresses), device and browser identifiers and information (including device, application, or browser type, version, plug-in type and version, operating system, user agent, language and time zone settings, and other technical information), advertising identifiers, cookie identifiers and information, and similar data.
e) Usage information: This includes usage metrics (including usage rates, occurrences of technical errors, diagnostic reports, settings preferences, backup information), content interactions (including searches, views, downloads, and prints), and user journey history (including clickstreams and page navigation, URLs, timestamps, content viewed or searched for, page response times, page interaction, and similar data.
f) Other Means: This includes from selected third-party business partners affiliated our Services and that we may utilise to deliver certain content, products, or Services, to enhance your experience or to acquire from third parties certain lists containing the names and contact information of individuals who may be interested in our Services.
i) “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
ii) “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
iii) “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.
More information about cookies and Tools can be found in Section 7 - Collection and Use of Other Data under the Cookies and Tools sub-heading.
We would like to assure our customers that we will only collect personal information that you knowingly and willingly provide by way of surveys, completed membership forms, and emails. We intend to only use such personal information for the intended purpose for which it was requested, ensure its accuracy, completeness, current relevance and any additional uses specifically provided on this Site.
We ask that you do not send, and you do not disclose, to us, any sensitive Personal Data (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through this Site or otherwise to us without our consent or request with relation to section 4(2) above on anonymous demographic information.
Our primary goal in collecting, using, and sharing your information is to enhance and improve in the operation of our website and to ensure delivery of the Services and products. To that end, we will only use Personal Data for legitimate business purposes, to manage our contractual relationship with you, and/or because we have a legitimate interest. This includes but is not limited to:
1. To provide you with information about products and Services you have ordered;
2. To process your payment information;
3. To arrange for shipping, and provide you with invoices and/or order confirmations;
4. To communicate with you and advertise our possible products, programs, Services and/or promotions;
5. To retarget advertisements;
6. Screen our orders to prevent potential risk or fraud (in particular, your IP address) and abuse to ensure the security and protection of all customers and others, such as to verify the existence or condition of your account;
7. With regards to completing surveys and/or research questionnaires related to your opinion of current or potential future Services that may be offered;
8. To gather information on behalf of other external business partners with regards to a potential new offer which may be of interest to you;
9. Follow websites and/or pages that our users may frequent in an effort to glean what types of services and/or products may be of special interest to customers or the general public;
10. Generally, to improve and optimise our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns);
11. For employees, agents and contractors to operate or maintain this Site or to correct a technical problem; and
12. To effectuate the sale, merger, acquisition, or other disposition of our assets or business (including in connection with any bankruptcy or similar proceedings).
Further explanation and clarification of in relation to the use of your information is provided below:
a) Promotions: This includes contests and similar promotions which may typically require further Personal Data when you enter and, if applicable, win a Promotion. You are encouraged to review the rules of each Promotion in which you participate, as they may contain additional important information about our use of Personal Data about you. To the extent that the terms and conditions of such rules concerning the treatment of your Personal Data conflict with this Policy, the terms and conditions of such rules shall control. We use this information to operate the Promotions.
b) Other Business Purposes: This includes data analysis (for example, to improve the efficiency of our Site and Services), editorial and feedback purposes, providing customer support, customising and improving the content and layout of this Site, completing business transactions (for example, to confirm content requested is received by users), development of marketing and promotion plans and materials, statistical analysis of user behaviour (for example, to understand what parts of this Site are of most interest to users), product development, market research, administering individual accounts, and meeting government regulatory requirements such as sales tax collection, audits, etc. Furthermore, we may also use Personal Data of journalist/media contacts for press release distribution or sharing other newsworthy developments related to our business activities.
If you consent or show interest in presented offers, then, at that time, specific identifiable information, such as name, email address and/or telephone number, may be shared with the third party.
We share your Personal Information with:
1. Third parties Service and/or data Providers: who provide services to us, including but not limited to, data analysis, order fulfilment, payment processing, and other services. We may be required to provide your Personal Data to the third party as part of our reporting obligations if your subscription to one of our products or Services contains third-party data which conditions your receipt of their data on knowing your identity.
2. Affiliate Communications: This allows our affiliates to contact you regarding products, programs, Services and promotions that they believe may be of interest to you, and such affiliates may otherwise use your Personal Data in accordance with this Policy.
3. Strategic Partners and Co-Branded Sites: This includes for the purposes of maintaining a special relationship with another company that is not owned by or affiliated with us to provide or promote joint products, services, applications, or features (together, “Jointly Offered Items”). These special relationships may include co-branded web sites (“co-branded pages”). Any information, including Personal Data that you provide in connection with one of these Jointly Offered Items, and/or on one of these co-branded pages will be shared with our third-party partners. If you do not want Personal Data about you shared with such third parties, please do not provide Personal Data in connection with the Jointly Offered Items and/or co-branded pages.
4. Conferences and Events: When you attend a conference or event organised by us, your name and contact information may be shared with other attendees.
5. Promotions: We may share the Personal Data you provide in connection with Promotions with third-party sponsors of such Promotions (irrespective of whether such Promotions are hosted by us), or otherwise in accordance with the rules applicable to those Promotions.
6. Assignment: We may disclose or transfer any and all Personal Data that we collect to an affiliated entity or a third party (and their respective advisors) in the event of any reorganisation, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).
7. Law Enforcement; Emergencies; Compliance: TW Media may only disclose your personal information without prior notice to you, if required to do so in accordance with:
a) Any applicable laws, rules, regulations, decrees, and/or statutes in any country in which we operate and including laws outside your country of residence;
b) Any legal processes which may be served upon TW Media and/or our website, such as to respond to an order or request from a court, regulator, or government authority, search warrant or other lawful request for information we receive;
c) Any requests from government or public authorities, including government and public authorities outside your country of residence;
d) Our legal obligations;
f) Our need to maintain, safeguard and/or preserve all the rights, privacy, safety and/or property of TW Media our affiliated entities, you, or others;
g) Our need to protect our operations or those of any affiliated entities;
h) Our need to permit us to pursue available remedies or limit the damages that we may sustain;
i) Our need to perform under demanding conditions in an effort to safeguard the personal safety of customers of TW Media and/or the general public; and
j) A good faith belief that such action is deemed necessary.
In addition, we may, to the fullest extent the law allows, disclose Personal Data about you to law enforcement agencies to assist them in identifying individuals who have been or may be engaged in unlawful activities.
Our service providers and we may also collect and use the following types of data, referred to in this Policy as “Other Data”:
a) Monitoring Data: This involves collecting and/or tracking other information such as demographic information, domain names, computer type, browser types, screen resolution, and other statistical data involving the use of this Site (“Monitoring Data”). We use Monitoring Data to help us understand who uses this Site and to improve and market it, as well as our other websites and services. Unless combined with Personal Data, Monitoring Data does not personally identify you or any other user, and we may use it for any purpose.
b) Aggregated Data: This involves aggregating Personal Data in a manner such that the end-product does not personally identify you or any other user of this Site, for example, by using information to calculate the percentage of our users who have a particular telephone area code. Such aggregate information may also be used for any purpose.
You can read more about how these sites use your Personal Information here:
e) IP Addresses: An Internet Protocol (IP) address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit this Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use IP addresses to understand how this Site is used by our users, to improve and administer this Site, to enhance user experience of this Site, to help diagnose problems with our server, and also to derive your approximate location from your IP address
i) Strictly Necessary: these cookies are essential to allow registered users to authenticate and perform account related functions, as well as to save the contents of virtual “carts” for e-commerce functionality.
ii) Analytics and Performance: Performance cookies collect information and understand on how users interact with our Services, including what pages are visited most, as well as other analytical data.
iii) Functionality: These cookies are used to store preferences set by users, such as account name and language.
iv) Security: these cookies help identify and prevent potential security risks.
v) Advertising: these cookies are used to display relevant advertising to users who use our Services, as well as to understand and report on the efficacy of adverts served on our Services. They track details such as the number of unique visitors, the number of times particular adverts have been displayed or clicked. They are also used to build user profiles, including showing you adverts based on products or Services you have viewed or acts you have taken.
vi) Third-Party / Embedded Content: Services hosted by us make use of different third-party applications and services to enhance the experience of our Services. As a result, cookies may be set by third parties, and used by them to track your online activity. We have no direct control over the information that is collected by these cookies.
As described above, TW Media may use third-party advertising companies and your Personal Information to provide you with targeted advertisements or marketing communications regarding products and Services we believe may be of interest to you based on information relating to your access to and use of this Site, our apps, other websites or online services on any of your devices. Third-party advertising companies may place or recognise a unique cookie on your browser (including through the use of pixel tags) and on other devices you use such as a mobile phone and a laptop.
For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work You can opt out of targeted advertising as per the following links:
FACEBOOK – https://www.facebook.com/settings/?tab=ads
GOOGLE – https://www.google.com/settings/ads/anonymous
Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
HubSpot - https://www.hubspot.com/products/marketing/analytics
Please note that we do not alter our Site’s data collection, use practices, or respond to Do Not Track (“DNT”) signals from your browser at this time. Various browsers offer a DNT option that sends a signal to third parties that you do not want to be tracked, however, some third-party sites may still track your actions when you are browsing and accessing content.
A “Data Controller” means a person who (either alone or jointly or in common with other persons) determined the purposes for which and the manner in which any Personal Data is, or will be, processed. For the purposes of this Policy, you are the Data Controller of your Personal Data and we are a processor on your behalf as to any Personal Data that is subject to the requirements of the United Kingdom’s Data Protection Act (DPA) 2018 and its regulations and principles. We may use the services of various third-party service providers in order to process your data more effectively
If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.
By transferring information or allowing information to be transferred to us, you consent to the transfer, processing and storage of your information in countries outside your country of residence where we have facilities or in which we engage service providers. If you are accessing this Site from outside the United Kingdom, you may be sending information, including Personal Data to the United Kingdom where our servers are located. However, that information may be transferred within or back out of the United Kingdom to other countries outside your country of residence. These countries do not necessarily have data protection laws as comprehensive as those in your country. Furthermore, in certain circumstances, courts, law enforcement agencies, regulatory agencies, or security authorities in those other countries may be entitled to access your Personal Data in accordance with the laws of that country.
You agree to update or correct your Personal Data whenever necessary. TW Media will use and retain your Personal Data for as long as is necessary and only according to its intended purpose for which it was collected, authorised by this Policy, authorised by you, consistent with applicable law and unless and until you ask us to delete this information. The criteria used to determine our retention periods include:
a) Length of time we have an ongoing relationship with you;
b) Whether there is a legal obligation to which we are subject; and
c) Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).
You expressly consent to the collection and use by us of Personal Data according to this Policy when you visit this Site. We give you choices regarding our use and disclosure of your Personal Data for marketing purposes. You may indicate your choices regarding marketing-related emails by contacting us via postal mail or telephone using our contact information below [see Section 19].
You have the option to, and/or reserve the right to, discontinue:
a) Receiving communications by way of email or newsletters from us or our affiliates; and/or
b) The sharing of your Personal Data on a going-forward basis with our affiliates or with unaffiliated third parties for their marketing purposes.
In order to do so, please send an email to email@example.com. We will try to comply with your request(s) as soon as reasonably practicable. Please note we will not be able to remove your Personal Data from the databases of our affiliates or unaffiliated third parties with which we have already shared your Personal Data prior to and as of the date upon which we implement your request. Further, by requesting us not to share your Personal Data with affiliates or unaffiliated third parties may result in you no longer receiving any marketing emails from us. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe and/or opt-out.
Additionally, please note that the option to opt-out of receiving information does not include circumstances where we need to maintain administrative communications with you in order to manage our contractual relationship with you and/or to comply with a legal obligation. The administrative communication will cease upon your termination and deletion of your account.
If you would like to request to review, correct, update, suppress, delete or otherwise limit our use of your Personal Data that has been previously provided to us, or if you would like to request to receive an electronic copy of your Personal Data for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may make a request by sending an email to firstname.lastname@example.org. We will try to comply with your request as soon as reasonably practicable and consistent with applicable law.
For your protection, we may only implement requests with respect to the Personal Data associated with your particular requesting email address and we may need to verify your identity before implementing your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to requesting the change or deletion and residual information that will remain within our databases and other records, which will not be removed.
We are committed to ensuring this Policy is accessible to disabled individuals. If you wish to access this Policy in an alternative format, please contact us by sending an email to email@example.com. Depending on the specific interactions you have with us, we may provide different or supplemental privacy statements that describe and govern how we use your personal information. When we do so, those different or supplemental privacy statements apply to those specific interactions you have with us.
TW Media shall take every precaution to maintain data accuracy, adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorised access, disclosure or modification of the user’s personal information under our control. Your Personal Data is used in accordance with existing laws, rules, regulations, and other policies and is stored on our server which is not publicly accessible.
TW Media uses Secure Socket Layer (SSL) for authentication and private communications in an effort to build users’ trust and confidence in the internet and website use by providing simple secure access, communication of credit card and personal information.
You recognise that there is no such thing as “perfect security” on the Internet from third-party “hackers” who illegally obtain your information. We are not responsible for the actions of any third parties and the breach of our security in obtaining any Personal Data. We do not make, and expressly disclaim, any representation or warranty, express or implied, regarding the security or integrity of this Site and your Personal Data.
You are prohibited from violating or attempting to violate security for or otherwise interfering with the operation of this Site. If you have reason to believe that your interaction with our Site is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please notify us immediately of the problem by sending an email to firstname.lastname@example.org.
Use of this Site is governed by the laws of England and Wales. By accessing this Site or Services from a physical location outside of the England and Wales with laws or regulations governing personal data collection, use, and disclosure that are different from the laws of England and Wales, you agree to transferring your Personal Data and any other data to the United Kingdom and you consent to the application of the laws of England and Wales with respect to use of this Site and Services and any dispute regarding this Site or this Policy. You further consent to the exclusive jurisdiction of, and agree that the courts of England and Wales are the proper venue for any legal dispute.
If any provision of this Policy is held by a court of competent jurisdiction to be illegal, unenforceable, or in conflict with any applicable law, the validity of the remaining portions or provisions shall remain in full force and effect.