Privacy Policy

Effective date: 12 November 2018.

The IMG Media website is operated by IMG Media Limited (company number 04459066 and registered office address Building 6 Chiswick Park, 566 Chiswick High Road, London, United Kingdom, W4 5HR) (“IMG”, “we”, “us” and “our”)

We take our obligations under applicable law seriously. We respect your privacy and value the trust you place in us when you share your personal information with us. This Privacy Policy sets out how we, as data controller, collect, hold, use, process and disclose your personal information, why and according to (?) what legal reasoning we process it, with whom and for (?) what purposes we share it, the rights to which you may be entitled, and your choices about our use of your personal information.

We are the data controller in relation to your personal information. This means that IMG collects, holds, uses and discloses your personal information in relation to the provision of the services to you, as well as for marketing and analytics, in accordance with the Terms of Use set out below.

This Privacy Policy covers our use of your personal information arising from use of the IMG website as well as registering / subscribing for our services.

If you have any questions or need any further clarity please get in touch. Contact details are set out below.

Please click on the sections below to learn more about our Privacy Policy:

DATA COLLECTION AND USAGE

WHY WE COLLECT YOUR INFORMATION

LEGAL REQUIREMENTS

HOW LONG WE KEEP YOUR INFORMATION

INFORMATION WE SHARE

WHERE YOUR INFORMATION WILL BE HELD

YOUR PRIVACY RIGHTS

COOKIES

SECURITY

LINKS TO THIRD PARTY WEBSITES

HOW TO CONTACT US

CHANGES TO THE POLICY

 

DATA COLLECTION AND USAGE

We will collect and use your personal information to:

  1. conduct our business;
  2. allow you to access this website and register for/subscribe to our services;
  3. meet our legal obligations;
  4. fulfil any purpose we make known to you when we collect your personal information; and
  5. fulfil other purposes set out in more detail in this section.

We may also use and disclose your personal information for any other purposes authorised by applicable law.

Your information will be shared with members of our group and some third parties as described below.

Some of the personal information we request is required to provide the services and if it is not provided, we may not be able to provide the relevant services to you.

The table below indicate what we collect, how we use it, and whether such information is required to provide services to you.

Any personal information you supply to us through the IMG website must be complete and accurate. You also agree to allow us to contact you to verify your personal information if we need to.

What we collect (type of personal information) How we use it (purpose) Why we use it (our legal basis for processing)
1 When you subscribe to the newsletter.

  • personal information you give us such as your name and e-mail address.
We use the information to send you our newsletters. The processing is based on your consent, as you have requested to receive such information, cf. GDPR, art. 6(1)(a).
2 Information about the way you use our services:

  • whether you’ve opened electronic communications from us; and
  • whether you’ve clicked on links in electronic communications from us.
We use this information to:

  • identify products and services that may be of interest to you;
  • personalise our service (e.g. offering recommended relevant content to you);
  • carry out statistical analysis and research;
  • improve our services; and
  • develop new services.
Collecting this information is in our legitimate business interests as it enables us to understand the type of products and services you buy and how you use them, allowing us to personalise content and improve our service to you, cf. GDPR, art. 6(1)(f).
3 Information when you communicate with us whether in person, via email, over the phone, through social media or via any other medium:

  • your contact details;
  • the details of your communications with us; and
  • the details of our messages to you.
We use this information, to:

  • respond to any issues or concerns;
  • monitor communications for quality and training purposes.
  • carry out statistical analysis and research;
  • improve our services;
  • personalise our services; and
  • develop new services.
Collecting this information is necessary to perform the contract, cf. GDPR, art. 6(1)(b), and it is in our legitimate business interests to improve our services and our relationship with you, cf. GDPR, art. 6(1)(f).
4 Information that we collect through your use of the IMG website:

  • technical information, including IP address, login information, browser type and version, time zone setting, browser plug-in types and versions, operating system, platform, device type, hardware model, MAC address, unique device identifiers and mobile network information;
  • information about your visit, including the full URL clickstream to, through and from the website (including date and time);
  • information about your network, such as information about devices, nodes, configurations, connection speeds, and network and application performance; and
  • pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs); and
  • methods used to browse away from the page.
We use this information to:

  • provide our services;
  • improve our services;
  • personalise our services;
  • identify products and services that may be of interest to you; (e.g. offering recommended relevant content to you);
  • develop new services;
  • identify issues with the website or app and user’s experience of them;
  • carry out statistical analysis and research into your behaviour when visiting the website; and
  • monitor the way the IMG website is used.
Collecting this information is necessary to perform the contract, cf. GDPR, art. 6(1)(b), and it is in our legitimate business interests to improve the services provided to you, cf. GDPR, art 6(1)(f).
5 Information that we collect from individuals representing organisations, including:

  • contact details of individuals working for organisations;
  • other personal information regarding such individuals.
We use this information to:

  • Provide our services;
  • Verify our customers’ identities and prevent fraud.
Collecting this information is necessary to perform the contract, cf. GDPR, art. 6(1)(b), and it is in our legitimate business interests to improve the services provided to you, cf. GDPR, art 6(1)(f).

We will also receive information about you (including your personal information) if you use any other websites or apps operated or other services provided by us or our group companies. In this case, that information will be shared within the IMG Media group and combined with information collected on the IMG website.

We also work closely with third parties (for example business partners, sub-contractors in technical services, advertising networks, analytics providers and search information providers).

WHY WE COLLECT YOUR INFORMATION

Some information processing is required for our anti-fraud screening or to verify our customers’ identities. In some jurisdictions, such screening and/or verification is not a legal requirement, whilst in others it is.

We also collect and use your information to keep you informed by email about new products, services and content that we believe may be of interest to you. We may notify you of such new products, services and content provided we have your consent to such notices (where consent is required, which can be withdrawn at any time by contacting us).

Your personal information will be processed as follows: if it is necessary on reasonable request by a law enforcement or regulatory authority, body or agency; to enforce or apply IMG’s Terms of Use and other agreements; in an emergency; to protect the rights, property or safety of IMG’s group companies, customers, clients and others; or in the defence of legal claims. We will not delete personal information if relevant to an investigation or a dispute or until applicable law allows for it to be deleted. It will continue to be stored until those issues are fully resolved and it can be lawfully deleted.

HOW LONG WE KEEP YOUR INFORMATION

We generally keep your information as needed to provide services and to deal with legal claims.

We will keep your information for as long as is reasonably necessary to deal with claims. We will also retain your information as necessary to comply with legal, accounting or reporting requirements.

We will also retain a copy of your contact details if you object or opt out of receiving direct marketing communications from us. We will add your details to our suppression list to ensure you do not receive any future marketing communications from us. Also, we will not delete personal data if relevant to an investigation or a dispute. It will continue to be stored until those issues are fully resolved.

INFORMATION WE SHARE

There are certain circumstances where we will transfer your personal data to employees, contractors and other parties.

We will share information about you with other members of our group of companies so we can provide the best service across our group.

Our suppliers and service providers will be required to meet our standards on processing information and security. The information we provide them, including your information, will only be provided in connection with the discharge (?) of their functions for us. Under our contracts with them, they would be prohibited from using or disclosing the information for their own purposes (?).

A list of parties to whom we will outsource the processing of your personal data, and transfer data for their own purposes, can be accessed here.

Your personal information will be transferred to other third-party organisations in certain scenarios if we are:

  • discussing selling or transferring part or all of our business – the information may be transferred to prospective purchasers and their advisors under appropriate terms as to confidentiality;
  • reorganised or sold – information may be transferred to a buyer who can continue to provide services to you;
  • required to by law, or under any regulatory code of practice we follow, or if we are asked by any public or regulatory authority – for example, law enforcement authorities;
  • defending a legal claim – your information may be transferred as required in connection with defending such claim; or
  • your personal data may be shared if it is made anonymous and aggregated, as in such circumstances the information will cease to be personal data.

WHERE YOUR INFORMATION WILL BE HELD

Your information may be transferred outside the European Economic Area (EEA).

The information that we collect from you may be transferred to and stored at a destination outside the EEA, including the USA which does not have equivalent data protection laws to those applicable to Europe. It may also be processed by staff operating outside the EEA who work for us, for one of our affiliated companies, or for the organisation that hosts our website.

However, to ensure your personal information is properly protected in line with EU data protection law, the transfer of this information is governed by a contract including Standard Contractual Clauses (SCCs) approved by the European Commission in accordance with article 46(2)(c) of the General Data Protection Regulation (GDPR).

We will only transfer data to jurisdictions outside the scope of the European GDPR where the appropriate safeguards set out in the GDPR are in place.

If you would like to obtain copies of the regulator-approved SSCs please contact us using the contact details below.

COOKIES

We use cookies that identify your browser. They collect and store information when you visit our website about how you use it, through which it is possible to monitor your use of the website, as well as provide you with a better service and experience when browsing the website, and undertake analytics. The personal data we collect through these technologies will also be used to manage your session.

For more information about cookies and how we use them, please see our Cookie Policy.

SECURITY

The transmission of information via the internet is not completely secure. Although we will take reasonable measures to protect your personal information, we cannot guarantee the security of your information transmitted through the IMG website and any transmission is at your own risk. Once we have received your personal information, we will use procedures and security features to try to prevent unauthorised access.

The IMG website, newsletters, email updates and other communications may, from time to time, contain links to and from the websites of others including members of our groups, our partner networks or advertisers and/or social networks as offered to you and supported by your browser. The personal data that you provide through those other websites is not subject to this Privacy Policy and the treatment of your personal data by the operators of such websites is not our responsibility. If you follow a link to any of these websites, please note that the operators of those websites may have their own privacy policies which set out how your information is collected and processed by them. For more information about the purpose and scope of data collection and processing in connection with social sharing features, please visit the privacy policies of entities through which you choose to share.

HOW TO CONTACT US
If you would like more information about the way we manage personal information that we hold about you or are concerned that we may have breached your privacy and wish to make a complaint, please contact us as set out below. We will do our best to resolve your complaint.

If you have any questions about this policy, please contact: IMG Media Limited (company number 04459066) at hellomedia@img.com or +44 20 8233 5000, or by post at Building 6, Chiswick Park, 566 Chiswick High Road, London W4 5HR, United Kingdom.

CHANGES TO THE POLICY

This Privacy Policy (inclusive of other policies referenced herein) represents the entire agreement among the parties on the subject matter hereof. Should any provision be held invalid by a court of competent jurisdiction, the remaining provisions shall continue in full force and effect.

This Privacy Policy may be updated from time to time.

If we wish to change anything in this Privacy Policy (e.g. the information we collect, how we use it or why) we will notify you through a pop-up which will be live for 30 days prior to the change and once the change has been made. You will receive the pop-up when you next access your user account after the pop-up has gone live. If you do not accept the changes to the Privacy Policy, we may not be able to provide the service to you. Hence, you have the right to terminate your subscription due to the changes of this Privacy Policy in accordance with section 7.C.VIII in the Terms of Use, upon one month’s notice to us or at the latest when the change enters into force.

Once this Privacy Policy is posted on the IMG website, it will automatically come into force. The latest version of this Privacy Policy will prevail over all previous versions and can be reviewed by visiting the IMG website and clicking on the “Privacy Policy” link.

Alternatively, you can email the Representative if you are in the EEA for previous versions.

A list of parties to whom we will outsource the processing of your personal data is below:

Name of the third party Data processing activities to be outsourced
dotdigital Email marketing