Privacy & Cookie Notice

Flixmedia Privacy Notice

1. Who are we?

Flixmedia Limited (“Company”, “we,”“our,” or “us”) is a company registered in England and Wales under registration number 05134871 and registered address of 650 Wharfedale Road, Winnersh Triangle, Wokingham, Berkshire, United Kingdom, RG41 5TP. We are the data controller for the purposes of this Privacy Notice. This Privacy Notice relates to Flixmedia with premises offering content syndication services. Flixmedia is part of the Advantage Smollan Group.

2. What is this Privacy Notice for?

This notice (“notice”) sets out how the Company uses, discloses, transfers and otherwise processes users’ personal data collected by communicating with Flixmedia electronically (e.g. email) or through their use of the Flixmedia website. It also describes how we use information collected from retailers’ websites, as outlined in section 12.
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Please keep in mind that the information collected on a retailer website is subject to the retailer’s privacy practices. You are not required to provide all personal data identified in this notice; however, be advised that if you choose not to provide certain Personal Information, we may be unable to provide some or all of the services to you, and your ability to use the website or services may be limited.

When we refer to ‘personal data’ in this Privacy Notice it means any information that relates to you from which you can be identified. This Privacy Notice governs the processing of your personal data, so please read it carefully.

3. What Personal Data may we collect?

We may collect the following personal data about you through the Flixmedia website:

• The contact details you provide (such as name, address, e-mail address, business or personal address, phone number) when working with Flixmedia.
• Payment details that we require for the purpose of processing any payments for work completed by Flixmedia on your instruction.
• Personal details you choose to give when corresponding with us by phone, email, online job application.
• Information you submit through any “Contact Us” feature, or otherwise provided to us in your communications with us.
• Usage, technical and device information when you visit our Site including browser or device information, unique device identifier, URL that referred you to our Site or Services, and IP address.
• Your log-in details to access our Flix360 or Measure Effect portal.

4. How we collect your data

Directly from You
We collect personal data you provide to us when you request services or information from us. Some areas of the website may require you to submit information, including personal data, to register for certain services or benefits, such as syndication services or when using the Flix360 or Measure Effect portal. We also collect your personal data when you sign up for our mailing and e-mail marketing lists, participate in a survey, contact us, or otherwise interact with our Site and Services.

When you use the Flixmedia website and Services
We and our service providers may collect information using analytics tools when you use our Site and Services such as Flix360 Manage Content and Measure Effect portals. These tools collect and store information about your interactions with our Sites and services. For details concerning the cookies and tracking technologies we use please read our Cookie Notice towards the end of this Notice.

5. How we use your data

We may use your personal data in the following ways:

• To operate our business and provide you with services you have requested.
• To display the content of this Site and any customisations you may select.
• To verify your identity.
• Open, maintain and administer accounts you open through our Sites or Services.
• To acknowledge, confirm, deal with and respond to your enquiry, job application, brief, order or other communication.
• Where we are asked to deal with any other enquiries or complaints you may make.
• To notify you about any changes to this Site, or services provided through this Site.
• To provide you with information about our services. Any such marketing communication that you receive from us will allow you to unsubscribe from these.
• To contact you in connection with user/customer/member surveys and use any information you choose to submit in response.
• For internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Site secure.
• On an aggregate basis, to understand how individuals collectively use the features of our Site.
• To give effect to your legal rights and your rights under this Privacy Notice.
• To protect against fraud, identity theft, and other unlawful activity.
• To establish or exercise any legal rights or claims.
• To satisfy our obligations under applicable law, this Privacy Notice, and any other policies or terms that are applicable to our relationship with you.
• For other purposes to which you have consented, and we may combine personal data that you provided to us with other information we collect about you for the purposes set out in this Privacy Notice.

6. Disclosure of your personal data

We may share your personal data with third parties in the following situations:

• We may disclose your personal data to our employees and agents to the extent necessary to provide you with the services you have requested.
• We may make your personal data available to selected third parties who act on our behalf to support our operations, for example card processing or payment services and credit reference agencies to protect against possible fraud, subject to appropriate contractual protections in accordance with applicable law.
• Our IT suppliers and contractors (e.g. data hosting providers or delivery partners) who may need to have access to your personal data to provide IT support and enable us to provide products and services, subject to appropriate contractual protections in accordance with applicable law.
• If we sell or transfer all, or any portion, of our business or our company assets to any third party, personal data held by us from you may be one of the transferred assets.
• To protect us or contractors against loss or damage (including without limitation, exchanging information with the police, courts or law enforcement organisations).
• To the extent necessary to establish, exercise or defend legal rights or claims, or for the purposes of investigating actual or suspected unlawful activity.

7. Security

We take the security of our clients’ data very seriously and we use appropriate measures to protect all personal information collected in a secure, controlled environment consistent with data protection legislation.

8. International transfers

Flixmedia use some third parties who are based outside of the UK and so your personal data may be transferred internationally. Where your data is shared to a country outside of the UK, we will ensure that necessary arrangements are in place to provide appropriate safeguards for your information. These arrangements may involve the use of an Adequacy Decision, Standard Contractual Clauses, the UK International Data Transfer Agreement or other permitted mechanism.

9. Lawful basis for processing

The UK and EU General Data Protection Regulation (GDPR) requires that we must have a lawful basis when processing (using) your information. We may rely upon one of the following lawful bases for the processing that we undertake:

10. Data Retention

We will only retain your personal data for as long as we require the personal data in connection with the purposes set out in this Privacy Notice, except where we are required, or permitted, under applicable law, to retain your personal data for additional periods of time.

11. Business to Business Marketing

As a part of our marketing practice, we make unsolicited contact with companies, including individual employees of such company, by telephone or email to inform them of our services that could result in a mutual commercial interest. We obtain the contact details for such companies and its employees from public information including company websites, business and social media, sector news and industry conferences. We also may have obtained such contact details directly from you or your company if you or your company have previously contacted us using a corporate phone number or corporate email address. Any personal data collected and processed for our business-to-business marketing practice as detailed herein is done so pursuant to our legitimate interest to market our services to you.

12. Information for Retailer Website Visitors

Our services involve offering content syndication on brands’ content and displaying this on retailer websites. In order to measure the effectiveness of our content syndication, we may place our cookie and other similar technology on your device when you use the retailer’s website. The technology will stay on your device for the duration of the session and collects the following information:

• Your IP address,
• Your local time,
• Whether you interacted with Flix content,
• Whether you had seen top of inpage, middle-of-inpage or bottom-of-inpage,
• Add to basket clicks (not all retailers),
• Your browser agent (can be used to infer - operating system, and occasionally the actual device model)
• Your time spent on the page (only if we syndicate content on that page),
• Whether you had seen the syndicated content on the page.

We keep your IP address for 24 hrs, before it is de-identified and then permanently erased. Flixmedia keeps all other information, which does not identify you, for 25 months. We only use the information collected to measure the effectiveness of the content shown to you. None of the information collected can identify you as an individual, nor can it be used to create a profile to help identify you as an individual.

The information collected will be shared with the following third parties:

• Google Cloud Platform: This is used to host and aggregate all of the information described above, except for the IP address.
• Amazon Web Services: All of the above information except IP addresses, are stored here in a log form.
• JW Player: Data is shared with JW Player so that they can provide streaming services to you.

13. Your Data Protection Rights

Under data protection law, you have the following rights in relation to your personal data:

• The right to request access to or copies of the personal data that we process.
• The right to rectify any inaccuracies in your personal data.
• The right to erasure of your personal data, in certain circumstances
• The right to restrict processing, in certain circumstances.
• The right to object to processing, in certain circumstances.
• The right to data portability, in certain circumstances.
• The right to withdraw your consent to our processing of your personal data, where consent is the lawful basis for the processing.
• Rights in relation to automated decision making and profiling; please note that Flixmedia do not undertake any automated decision making or profiling.

If you wish to exercise any of the rights listed in this section, please select this LINK and complete the online form. We may also need to ask you for further information to verify your identity before we can respond to any request.

14. Change to our Privacy Notice

If we change this Privacy Notice, we will let you know about the changes by publishing the updated version on our website: https://www.flixmedia.com. We are committed to protecting and respecting your privacy and will continue to do so in any future changes we make to this Privacy Notice.

15. Contact

Questions, comments or requests regarding this Privacy Notice or any of our processing should be made to our Data Protection Officer. Our Data Protection Officer can be contacted by completing the form available via this LINK or post at: Data Privacy, 14 – 16 Well Court, Farringdon Lane, London, EC1R 3AU, UK.

For EU individuals, Flixmedia has an EU representative, based in The Netherlands, who can also be contacted via this LINK.

16. The right to lodge a complaint with a supervisory authority

The right to lodge a complaint with a supervisory authority You have the right to complain to your supervisory authority. For individuals based in the UK, this is the Information Commissioners Office who you can contact by following this link: https://ico.org.uk/make-a-complaint/  

17. Flixmedia’s Cookies and Similar Technology placed on Retailer Websites

As part of our services, we may place Cookies and Similar Technology, on the devices of shoppers visiting the website of retailers which display our content syndication. The Cookies and Similar Technology do the following:

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