NLA media access Limited (“We/ the NLA”) are committed to protecting and respecting your privacy.
(together “Content Websites”),
(together “Corporate Websites”),
For the purpose of the General Data Protection Regulation 2016/679 and the Data Protection Act 2018 (“the Act”) and any subsequent legislation, the Data Controller is NLA media access Limited of Mount Pleasant House, Lonsdale Gardens, Tunbridge Wells, Kent, TN1 1HJ.
INFORMATION WE COLLECT FROM YOU
We will collect and process the following data about you:
• Information you give us. This is information about you that you give us by filling in forms on our Websites or by corresponding with us by phone, e-mail or otherwise (including by completing any surveys). The information you give us may include your name, address, e-mail address, phone number, financial and credit card information.
• Information we collect about you. With regard to each of your visits to our Websites we may automatically collect information including:
• technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
• information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our Websites (including date and time), products you viewed, search terms, page response times, download errors, duration of page visits, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page and any phone number used to call our customer service number.
• Information we obtain in other situations. This includes information we obtain on CCTV and/or biometric readers at or in our offices, or voice recordings in the course of any recorded telephone communications.
• Information we receive from other sources. This is information we may collect from third party sources as well as publicly available sites and social media platforms where such processing is fair and lawful.
• We may receive contact details from Media Monitoring Organisations ("MMOs") of a contact person at each of their clients to whom the MMOs provide content pursuant to their NLA licences. We use this information to contact potential licensees who may require licences.
• We may receive e-mail addresses and usernames from MMOs and their clients, and of individuals at those clients who wish to access articles via our eClips databases. Such individuals provide us with their usernames and passwords. We use this information to provide the selected individuals with access to such articles. We use this additional data to monitor use of our eClips database and to detect and prove infringement of our rights and/ or breach of licence terms.
• We may make written notes of telephone conversations we have with individuals at potential licensee companies (in relation to their need for a licence and the applicable terms) and existing licensee companies (in relation to their existing licence, renewals, etc), and of relevant contact numbers, job titles and names. We use this information to enable us to ascertain which organisations require licences, and to take steps to encourage organisations to take and renew licences.
• We may also work with third parties (including, for example, business partners and sub-contractors in technical, payment and delivery services, advertising networks, as well as analytics providers, and search information providers).
• Where we act as a Data Processor for our clients we will comply with our obligations as a processor and subject to such instructions and contractual controls as our clients impose upon us in their capacity as Data Controller.
Cookies are small files of letters and numbers stored by the web browser on the hard drive of an internet user's computer or other device. For more detail on what cookies are and how they work, please see allaboutcookies.org.
Individuals can block cookies by activating the setting on their internet browser that allows them to refuse the setting of all or some cookies. However, if individuals use their browser settings to block all cookies (including essential cookies), they may not be able to access parts of our website.
On some Content Websites, in order to avoid the user having to re-enter their login details each time they access the databases, the NLA uses "remember me" cookies. These cookies encrypt and store the user's username and password on the user's computer/ device. When the user next seeks to access one of the databases, the cookie enables the user to be identified without having to re-enter their login details. These cookies will expire after a period of time which varies by site.
THE LEGAL BASIS FOR PROCESSING YOUR PERSONAL DATA
In order to comply with applicable data privacy laws, we are required to set out the legal basis for the processing of your Personal Data. In accordance with the purposes for which we collect and use your Personal Data, as set out above, the legal basis for processing your Personal Data will typically be one of the following:
• our own or our third parties’ legitimate business interests (for example, in maintaining and promoting our business by providing customers with feedback opportunities or other instances where we have carried out a legitimate interests assessment and have established an existing legitimate interest);
• the performance of a contract that we have in place with you;
• your consent where appropriate; or
• compliance with our legal obligations.
USES MADE OF THE INFORMATION
We use information held about you in the following ways:
• Information you give to us. We will use this information:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and services that you request from us;
• to provide you with information about other goods and services we offer that are similar to those that you have already purchased or enquired about;
• to notify you about changes to our service;
• to ensure that content from our site is presented in the most effective manner for you and for your computer.
• Information we collect about you. We will use this information:
• to administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve our site to ensure that content is presented in the most effective manner for you and for your computer;
• as part of our efforts to keep our site safe and secure;
• Information we receive from other sources. We will combine this information with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with selected third parties including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimisation of our site.
We will disclose your personal information to third parties including:
• In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets;
• If the NLA or substantially all of its assets are acquired by a third party, in which case personal data held by the NLA will be one of the transferred assets;
WHERE WE STORE YOUR PERSONAL DATA
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
We will keep your personal data for as long as we need it, or as otherwise prescribed by law, for the purposes set out above, and so this period will vary depending on your interactions with us. Please note that where you unsubscribe from our marketing communications, we will keep a record of your email address to ensure we do not send you marketing emails in future.
You have the right to ask us not to process your personal data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing by checking certain boxes on the forms we use to collect your data. You can also exercise the right at any time by using your preference centre on our site.
Our site may, from time to time, contain links to and from the websites of other third parties. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.
SOCIAL MEDIA FEATURES
Our site is directed at an adult audience and we do not knowingly collect information from or about children.
DATA SUBJECT RIGHTS
Data subjects in the EEA and other jurisdictions may have rights in relation to their personal data which include:
• Right to rectification. Data subjects may request that we rectify any inaccurate or incomplete personal data.
• Right to withdraw consent. Data subjects may at any time withdraw their consent to the processing of their personal data carried out by us on the basis of their previous consent. Such withdrawal will not affect the lawfulness of processing based on such previous consent.
• Right to make a subject access request (SAR). Data subjects may request in writing copies of their personal data. However, compliance with such requests is subject to certain limitations and exemptions and the rights of other individuals. Each request should make clear that a SAR is being made. You may also be required to submit a proof of your identity and any payment permitted by law, where applicable.
• Right to object to processing including automated processing and profiling. We do not make automated decisions about data subjects. However, we may rely on information provided by third parties such as credit reference agencies which may score data subjects on the basis of automated decisions. Profiling may be carried out for business administration purposes, such as monitoring trends in user visits of our website. We will comply with valid objection requests unless we have a compelling overriding legitimate ground for the continuation of our processing or we have another lawful reason to refuse such request. We will comply with each valid opt-out request in relation to marketing communications.
• Right to erasure. Data subjects may request that we erase their personal data. We will comply, unless there is a lawful reason for not doing so. For example, there may be an overriding legitimate ground for keeping the personal data, such as, our business record retention obligations that we have to comply with.
• Restriction. Data subjects may request that we restrict our processing of their personal data in various circumstances. We will comply, unless there is a lawful reason for not doing so, such as, a legal obligation to continue processing your personal data in a certain way.
• Right to data portability. In certain circumstances, data subjects may request the controller to provide a copy of their personal data in a structured, commonly used and machine-readable format and have it transferred to another provider of the same or similar services. We do not consider that this right applies to our Services. However, to the extent it does, we will comply with such transfer request. Please note that a transfer to another provider does not imply erasure of the data subject’s personal data which may still be retained for legitimate and lawful purposes.
• Right to lodge a complaint with the supervisory authority. We suggest that data subjects contact us about any questions or complaints in relation to how we process their personal data. However, each data subject has the right to contact the relevant supervisory authority directly.