Privacy & Cookie Policy

1.Privacy Policy Statement

 

MediaPath Compliance respects your right to privacy. This policy summarises what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

It is MediaPath Compliance’s policy to comply with all applicable privacy and data protection laws. This commitment reflects the value we place on earning and keeping the trust of our customers, business partners and others who share their personal information with us.

This policy applies to all internet sites and mobile applications (apps) operated by or on behalf of MediaPath Compliance. It also applies to personal information MediaPath Compliance may otherwise collect:

  1. through our products and services;

  2. when you interact with us by means other than a MediaPath Compliance internet site or app, for example, in person, by telephone, or at a trade show; and

  3. from our customers, distributors, suppliers, vendors, and other business partners (collectively ‘Business Partners’).

 

 

2.General principles

 

To the extent required by applicable law, whenever MediaPath Compliance collects personal information, MediaPath Compliance will:

  1. provide timely and appropriate notice to you about our data practices;

  2. collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;

  3. process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;

  4. take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;

  5. not use your personal information for direct marketing purposes without giving you an opportunity to ‘opt-out’; and

  6. take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within MediaPath Compliance.

 

 

3.Personal information MediaPath Compliance collects

 

MediaPath Compliance collects the following types of personal information:

 

Information you provide

MediaPath Compliance collects personal information you provide us, which may include:

  1. contact information, such as your name, company name, job title, address, e-mail address, and phone number;

  2. additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products or services, and demographic information;

  3. comments, questions, requests and orders you may make;

  4. financial information needed to process payments if you make purchases, such as credit card or account information or tax identification number;

  5. log-in information, including, if applicable, social media account information for login purposes;

  6. information about your preferences, such as your preferred methods of communication and product/service types in which you are interested.

 

Information automatically gathered from your device

Device and browser information

MediaPath Compliance may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. MediaPath Compliance collects this information automatically from your device and web browser through cookies and similar technologies.

Information about how you interact with us

MediaPath Compliance may collect technical data about your usage of the MediaPath Compliance internet site and apps and how you interact with our digital advertisements and promotions, such as content viewed or downloaded, features used, links clicked, MediaPath Compliance promotional emails opened, and dates and times of interactions. MediaPath Compliance collects this information using cookies and similar technologies.

Location information

MediaPath Compliance may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. The MediaPath Compliance internet site and apps will not access precise-real time location information from your device unless you grant permission to do so.

 

Cookies and similar technologies

A ‘cookie’ is a file of information placed on your device when you visit a website. Cookies and similar technologies can enhance your user experience by saving your preferences, personalising your online experience, holding items in your shopping cart, and sometimes providing you with advertising which is tailored to your interests.

The MediaPath Compliance internet site uses ‘session cookies’. A session cookie does not identify you personally and expires after you close your browser. For example, when you use the MediaPath Compliance internet site, we place a session cookie to note what pages you have viewed. We can use this information to provide you recommendations for other products or services that may be of interest.

The MediaPath Compliance internet sites also uses ‘persistent cookies’. These cookies do not expire when you close your browser. Persistent cookies stay on your computer until you delete them or they expire. By assigning your computer a unique identifier, we are able to create a database of your previous choices and preferences which can be provided by us automatically, saving you time and effort on future visits.

Certain countries require your consent to the use of cookies when you visit the MediaPath Compliance internet site. If you access the MediaPath Compliance internet site, you will be presented with information regarding your options, including the option to accept or reject certain categories of cookies. You will be able to change these settings on subsequent visits. Please note that you will not be able to opt out of receiving certain cookies that are strictly necessary for the delivery of a service requested by you.

Although you are not required to accept cookies when you visit the MediaPath Compliance internet site, you may be unable to use all of the functionality of the site if you reject certain cookies.

In addition, your browser may allow you to adjust settings to accept or reject cookies, or to alert you when a cookie is placed on your computer.

 

Analytics and advertising

MediaPath Compliance may use third party analytics services to better understand how users engage with the MediaPath Compliance internet site and apps, including services provided by Google and Adobe. Please use the following links for more information about how Google and Adobe collect and use data when you visit their partners’ websites or apps:

www.google.com/policies/privacy/partners/

www.adobe.com/privacy/marketing-cloud.html

MediaPath Compliance may also use third party advertising services to provide advertisements for MediaPath Compliance products or services that may be of interest to you when you visit websites or other online services.

MediaPath Compliance may allow selected third parties, including these analytics and advertising services, to place cookies on our internet site. These third parties may collect information about your online activities over time and across third party websites.

These third parties may be members of industry self-regulatory groups such as the Network Advertising Initiative (NAI), Digital Advertising Alliance (DAA) and European Digital Advertising Alliance (eDAA). The websites for these groups provide more information on interest-based online advertising and how to opt out of receiving interest-based online ads from participating companies.

 

Do Not Track browser settings

Some browsers may transmit “Do Not Track” (‘DNT’) signals to the websites you visit. Because there is no common agreement about how to interpret DNT signals, MediaPath Compliance currently does not take action in response to them.

 

Information from Business Partners and other third parties

MediaPath Compliance may collect personal information through our Business Partners. This information may include contact information, such as name, company name, job title, address, email address and phone number.

MediaPath Compliance may also obtain personal information from other third party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third party sources with information that we collect from you or your device, as described above.

You have choices about the personal information you provide to MediaPath Compliance. You may choose not to provide information that we request, but if you do so, we may not be able to provide you with a particular product or service.

 

 

4.How MediaPath Compliance uses your personal information

 

MediaPath Compliance may use your personal information to:

Develop and manage our relationships with you and our Business Partners. This may include:

  1. delivering services or carrying out transactions that you or our Business Partners have requested;

  2. providing information about MediaPath Compliance products, services, and transactions, and advertisements, that may be of interest to you;

  3. providing you and our Business Partners a more consistent experience in interacting with MediaPath Compliance, including by learning more about you and how you use and interact with the MediaPath Compliance internet site or our products and services; and

  4. planning, managing, and performing under our contractual relationships with you or our Business Partners.

Communicate with you or your company. This may include:

  1. informing you of MediaPath Compliance products, services, and promotional activities that may be of interest to you or your company;

  2. providing information about relevant MediaPath Compliance products, services, and transactions, including, for example, pricing information, technical data, invoices or service information;

  3. responding to questions or inquiries that you make, including customer service requests; and

  4. inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.

Provide and improve our internet site and services. This may include:

  1. customising them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use;

  2. maintaining the security of and otherwise protecting them; and

  3. developing new MediaPath Compliance internet sites, apps and services.

Address legal issues. This may include:

  1. complying with our obligations to retain certain business records for minimum retention periods;

  2. establishing, exercising, or defending legal claims;

  3. complying with laws, regulations, court orders, or other legal process;

  4. detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of the MediaPath Compliance internet sites or services; and

  5. protecting MediaPath Compliance’s rights or property, or yours or others’ health, safety, welfare, rights, or property.

MediaPath Compliance may also use your personal information for other uses consistent with the context in which the information was collected or with your consent.

MediaPath Compliance may anonymise or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

 

 

5.When MediaPath Compliance may share your personal information

 

MediaPath Compliance will not disclose your personal information except as described here:

MediaPath Compliance may share your personal information with other MediaPath Compliance entities, including those in different countries. When we do so, these other MediaPath Compliance entities will use your information in a manner consistent with this policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.

MediaPath Compliance may also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.

In some cases, MediaPath Compliance may share your personal information with third parties who partner with us to provide products and services to our customers. If so, we will require our Business Partners to use that information in a manner consistent with this policy, any applicable specific privacy policies and statements, and all applicable privacy and data protection laws.

MediaPath Compliance may share your personal information with third parties when we have a good faith belief that disclosure is necessary:

  1. to comply with a law, regulation, court order, or other legal process;

  2. to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of the MediaPath Compliance internet site or services;

  3. to protect MediaPath Compliance’s rights or property or yours or others’ health, safety, welfare, rights, or property; or

  4. under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.

MediaPath Compliance may share your personal information with third parties in connection with the sale, purchase, merger, reorganisation, liquidation or dissolution of MediaPath Compliance. If such an event occurs, we will take appropriate steps to protect your personal information.

MediaPath Compliance may share your information with your permission or at your request.

MediaPath Compliance may share anonymised or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

 

 

6.Security of your personal information

 

Storage

Your personal information will generally be stored in MediaPath Compliance databases or databases maintained by our service providers. MediaPath Compliance takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within MediaPath Compliance.

MediaPath Compliance maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorised disclosure, misuse, or alteration, as is the case with all computer networks linked to the internet, we cannot guarantee the security of information provided over the internet and will not be responsible for breaches of security beyond our reasonable control.

 

Links to third party internet sites and plugins

The MediaPath Compliance internet site and apps may contain links to other internet sites or apps that are not operated by MediaPath Compliance and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook link button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.

 

Access to your personal information

You may review, correct and update personal information you provide to us by contacting us.

 

Retention of your personal information

How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.

 

Children

The MediaPath Compliance internet site is not intended for children under 13 years of age. MediaPath Compliance will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.

 

Additional Information for EU residents

Data controller and contact information

The controller for personal data collected under this Privacy Policy is MediaPath Compliance Limited.

You can find the contact details of MediaPath Compliance Limited on our internet site.

MediaPath Compliance’s lawful basis for processing your personal data

The lawful basis for MediaPath Compliance’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for MediaPath Compliance’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law.

Processing on the basis of legitimate business interests

When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include:

  1. providing, improving, and promoting the MediaPath Compliance internet sites and our services;

  2. communicating with current and potential customers, other Business Partners, and their individual points of contact;

  3. managing our relationships with our customers and other Business Partners, and their individual points of contact;

  4. other business development purposes;

  5. sharing information within MediaPath Compliance, as well as with service providers and other third parties; and

  6. maintaining the safety and security of our products, services and employees, including fraud protection.

Processing on the basis of performance of a contract

Examples of situations in which we process personal information as necessary for performance of a contract include the provision of MediaPath Compliance’s services.

Processing on the basis of consent

Examples of processing activities for which MediaPath Compliance uses consent as its legal basis include:

  1. collecting and processing precise location information from your mobile device;

  2. sending promotional emails when consent is required under applicable law; and

  3. processing personal data on the MediaPath Compliance internet site through cookies and similar technologies when consent is required by applicable law.

Processing because MediaPath Compliance is under a legal obligation to do so

Examples of situations in which MediaPath Compliance must processes personal data to comply with its legal obligations include:

  1. payment of taxes and other government levies;

  2. providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws;

  3. retaining business records required to be retained by applicable laws; and

  4. complying with court orders or other legal process.

 

Additional information about the retention of your personal data

To determine the period for which your personal data will be retained in accordance with this policy, MediaPath Compliance considers criteria such as:

  1. any applicable legal requirements to retain data for a certain period of time;

  2. any retention obligations related to actual or potential litigation or government investigations;

  3. any retention requirements in relevant agreements with our Business Partners;

  4. the date of your last interaction with MediaPath Compliance (including with the MediaPath Compliance internet sites, communications, etc.);

  5. the length of time between your interactions with MediaPath Compliance;

  6. the sensitivity of the data; and

  7. the purposes for which the data was collected.

 

 

7.GDPR and your individual rights

 

In accordance with the applicable laws in the UK, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. You can exercise your rights by contacting us.

 

Right of access

You have the right to ask MediaPath Compliance to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information

  1. the purposes of the processing;

  2. the categories of personal data we process;

  3. the recipients or categories of recipients of your personal data;

  4. the envisaged retention period of the data where possible, or the criteria we use to determine the retention period;

  5. your right to request rectification or erasure of your personal data, or restriction of the processing of such data;

  6. your right to file a complaint with a supervisory authority;

  7. if we have not collected the data from you, any information we have available about the source of the data; and

  8. whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you.

 

Right to rectification

You have the right to have MediaPath Compliance correct your personal data if it is inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to MediaPath Compliance.

 

Right to object to processing for MediaPath Compliance’ legitimate business interests

You have the right to object to MediaPath Compliance processing your personal data when that data is processed on the basis of MediaPath Compliance’s legitimate business interests. MediaPath Compliance will honour your objection and stop processing the relevant personal data unless:

  1. we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or

  2. we need to continue processing your personal data to establish, exercise, or defend a legal claim.

 

Right to object to processing for direct marketing

If MediaPath Compliance processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, MediaPath Compliance will stop processing your personal data for direct marketing purposes.

 

Right to restrict processing

You have the right to request that MediaPath Compliance restricts the processing of your personal data in the following circumstances:

  1. for the period of time MediaPath Compliance needs to verify the accuracy of your personal data when you contest its accuracy;

  2. when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that MediaPath Compliance restrict the use of the data;

  3. when MediaPath Compliance no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or

  4. for the period of time MediaPath Compliance needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for MediaPath Compliance’s legitimate business interests.

If following your request MediaPath Compliance restricts the processing of your personal data, MediaPath Compliance will store your data, and otherwise process it only with:

  1. your consent;

  2. to establish, exercise, or defend a legal claim;

  3. to protect the rights of another natural or legal person; or

  4. for reasons of important public interest.

MediaPath Compliance will also inform you before lifting the restriction of processing.

 

Right to erasure

The right to erasure is also called the ‘right to be forgotten’. You may ask MediaPath Compliance to delete your personal data. This right not absolute. MediaPath Compliance is required to delete your personal data upon your request only in the following circumstances:

  1. your personal data is no longer necessary for the purposes for which MediaPath Compliance collected or processed them;

  2. if MediaPath Compliance processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for MediaPath Compliance to continue processing your personal data;

  3. if MediaPath Compliance processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for MediaPath Compliance to continue processing your personal data;

  4. if MediaPath Compliance has processed your personal data unlawfully; or

  5. the personal data must be erased to comply with a legal obligation under the laws to which MediaPath Compliance is subject.

MediaPath Compliance is not required to erase your personal data to the extent that MediaPath Compliance needs to process them to:

  1. exercise its right of freedom of expression and information;

  2. comply with a legal obligation under the law to which MediaPath Compliance is subject; or

  3. to establish, exercise, or defend a legal claim.

 

Right to data portability

You have the right to receive personal data you provided to MediaPath Compliance when:

  1. the processing of the data is based on your consent or is necessary for the performance of a contract between you and MediaPath Compliance;

  2. MediaPath Compliance’s processing of your personal data is carried out by automated means; and

  3. complying with your request will not adversely affect the rights and freedoms of others.

If you have the right to receive such personal data and request that MediaPath Compliance provide it, MediaPath Compliance will provide it to you in a structured, commonly used, and machine-readable format.

 

Right to lodge a complaint with a supervisory authority

MediaPath Compliance will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.

 

 

8.Questions about this Policy or our Privacy Statements

 

If you have any questions about this Policy or our use of your personal information, please contact MediaPath Compliance. Our contact details are provided on our internet site.

 

 

9.Changes to this Policy and our Privacy Statements

 

Changes to this Privacy Policy will be posted on the MediaPath Compliance website, along with information on any material changes. MediaPath Compliance reserves the right to update or modify this policy at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.

 

 

10.Policy Implementation and Commitment

 

This policy took effect from 22 January 2021.

This policy is integral to MediaPath Compliance’s operations and is periodically reviewed by the Company Directors. The Company Directors are committed to the implementation and ongoing monitoring of this policy.