Privacy Policy
This privacy notice for Who Media Ltd (‘Company’, ‘we’ or ‘our’), describes how and why we
might collect, store, use and/or share (‘process’) your information when you use our services
(‘Services’), such as when you:
Visit our website at http://whomedia.digital, or any website of ours that links to this privacy
policy
Engage with us in other related ways, including any sales, marketing or events
Questions or concerns regarding this privacy policy will help you understand your privacy
rights and choices. If you do not agree with our policies and practices, please do not use our
Services. If you still have any questions or concerns. Please contact us at
info@whomedia.digital
What personal information do we process?
When you visit, use or navigate our Services, we may process personal information
depending on how you interact with Genico Digital Ltd and the Services, the choices you
make, and the products and features you use.
Do we process any sensitive personal information?
We do not process sensitive personal information.
Do we receive any information from third parties?
We do not receive any information from third parties.
How do we process your information?
We process your information to provide, improve, and administer our Services, communicate
with you, for security and fraud prevention, and to comply with law. We may also process
your information for other purposes with your consent. We process your information only
when we have a valid reason to do so.
In what situations and with which types of parties do we share personal information?
We may share information in specific situations and with specific categories of third parties.
What are your rights?
Depending on where you are located geographically, the applicable privacy law may mean
you have certain rights regarding your personal information.
How do you exercise your rights?
The easiest way to exercise your rights is by filling out our data subject request form which is
available here, or by contacting us. We will consider and act upon any request in accordance
with applicable data protection laws.
What Information Do We Collect?
Personal information you disclose to us.
In Short: We collect personal information that you provide to us.
We collect personal information that you voluntarily provide to us when you express and
interest in obtaining information about us or our products and Services, when you participate
in activities on the Services, or otherwise when you contact us.
Personal Information Provided by You
The personal information that we collect depends on the context of your interactions with us
and the Services, the choices you make, and the products and features you use. The
personal information we collect may include the following:
Names
Phone numbers
Email addresses
Sensitive Information
We do not process sensitive information.
All personal information that you provide to us must be true, complete and accurate, and you
must notify us of any changes to such personal information.
Information automatically collected
In Short: Some information – such as your Internet Protocol (IP) address and/or browser and
device characteristics – is collected automatically when you visit our Services.
We automatically collect certain information when you visit, use, or navigate the Services.
This information does not reveal your specific identity (like your name or contact information)
but they may include device and usage information, such as your IP address, browser and
device characteristics, operating system, language preferences, referring URLs, device
name, country, location, information about how and when you use our Services, and other
technical information. This information is primarily needed to maintain the security and
operation of our Services, and for our internal analytics and reporting purposes.
Like many businesses, we also collect information through cookies and similar technologies.
The information we collect includes:
Log and Usage Data
Log and usage data is a service-related, diagnostic, usage, and performance information our
servers automatically collect when you access or use our Services and which we record in
log files. Depending on how you interact with us, this log data may include your IP address,
device information, browser type, and setting and information about your activity in the
Services (such as the date/time stamps associated with your usage, pages and files viewed,searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
Location Data
We collect location data such as information about your device’s location, which can be
either precise or imprecise. How much information we collect depends on the type and
settings of the device you use to access the Services, e.g. we may use GPS and other
technologies to collect geolocation data that tells us your current location (based on your IP
address). You can opt out of allowing us to collect this information either by refusing access
to the information or by disabling your location setting on your device. However, if you
choose to opt out, you may not be able to use certain aspects of the Services.
How Do We Process Your Information?
In Short: We process your information to provide, improve, and administer our Services,
communicate with you, for security and fraud prevention, and to comply with law. We may
also process your information for other purposes with your consent.
We process your personal information for a variety of reasons, depending on how you
interact with our Services, including:
To deliver and facilitate delivery of services to the user
We may process your information to provide you with the requested service.
To respond to use enquiries/offer support to users
We may process your information to respond to your enquiries and solve any potential
issues you might have with the requested service.
To send administrative information to you
We may process your information to send you details about our products and Services,
changes to our terms and policies, and other similar information.
To fulfill and manage your orders
We may process your information to fulfill and manage your orders, payments, returns and
exchanges made through the Services.
To enable user-to-user communications
We may process your information if you choose to use any of our offerings that allow for communication with another use
To save or protect an individual’s vital interestWe may process your information when necessary to save or protect an individual’s vital
interest, such as to prevent harm.
What Legal Bases Do We Rely on to Process Your Information?
In Short: We only process your personal information when we believe it is necessary and we
have a valid reason, (i.e., legal basis), to do so under applicable law, like with your consent,
to comply with laws, to provide you with services to enter into or fulfill our contractual
obligations, to protect your rights, or to fulfill our legitimate business interests.
The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the
valid legal bases we rely on in order to process your personal information. As such, we may
rely on the following legal bases to process your personal information:
Consent
We may process your information if you have given us permission (i.e., consent) to use your
personal information for a specific purpose. You can withdraw your consent at any time.
Performance of a Contract
We may process your personal information when we believe it is necessary to fulfill our
contractual obligations to you, including providing our Services or at your request prior to
entering into a contract with you.
Legal Obligations
We may process your information where we believe it is necessary for compliance with our
legal obligations, such as to cooperate with a law enforcement body or regulatory agency,
exercise or defend our legal rights, or disclose your information as evidence in litigation in
which we are involved.
Vital Interests
We may process your information where we believe it is necessary to protect your vital
interests or the vital interests of a third party, such as situations involving potential threats to
the safety of any person.
When and With Whom Do We Share Your Personal Information?
In Short: We may share information in specific situations described in this section and/or with
the following categories of third parties.
Vendors, Consultants and Other Third-Party Service Providers
We may share your data with third-party vendors, service providers, contractors, or agents
(‘third parties’) who perform services for us or on behalf and require access to suchinformation to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do
anything with your personal information unless we have instructed to them do it. They will also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as
follows:
Data analytic services
Performance monitoring tools
Retargeting platforms
Sales & Marketing tools
Social networks
Website hosting service providers
We may also need to share your personal information in the following situations:
Business Transfers
We may share or transfer your information in connection with, or during negotiations of, any
merger, sale of company assets, financing or acquisition of all or a portion of our business to
another company.
When we Use Google Maps Platform APIs
We may share your information with certain Google Maps Platform APIs, e.g. Google Maps
API and Places API.
Do We Use Cookies and Other Tracking Technologies?
In Short: We may use cookies and other tracking technologies to collect and store your
information.
We may use cookies and similar tracking technologies (like web beacons and pixels) to
access or store information. Specific information about how we use such technologies and
how you can refuse certain cookies is set our in our Cookie policy.
How Long Do We Keep Your Information?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in
this privacy policy unless otherwise required by law.
We will only keep your personal information for as long as it is necessary for the purposes
set out in this privacy policy, unless a longer retention period is required or permitted by law
(such as tax, accounting, or other legal requirements). No purpose in this policy will require
us keeping your personal information for longer than 1 year.
When we have no ongoing legitimate business need to process your personal information,
we will either delete or anonymise such information, or, if this is not possible, e.g. becauseyour personal information has been stored in backup archives, when we will securely store your personal information and isolate it from any further processing until deletion is possible.
Do We Collect Information from Minors?
In Short: We do not knowingly collect data from or market to children under 18 years of age.
We do not knowingly solicit data from or market to children under the 18 years of age. By
using the Services, you represent that you are at least 18 or that you are the parent or
guardian of such a minor and consent to such minor dependent’s use of the Services. If we
learn that personal information from users less that 18 years of age has been collected, we
will deactivate the account and take reasonable measures to promptly delete such data from
our records. If you become aware of any data we have collected from children under age 18,
please contact us at info@whomedia.digital.
What Are Your Privacy Rights?
In Short: In some regions, such as the European Economic Area (EEA) and United Kingdom
(UK), you have rights that allow you greater access to and control over your personal
information. You may review, change or terminate your account at any time.
In some regions (like the EEA and UK), you have certain rights under applicable data
protection laws. These may include the right (i) to request access and obtain a copy of your
personal information: (ii) to request rectification or erasure; (iii) to restrict the processing of
your personal information; and (iv) if applicable, to data portability. In certain circumstances,
you may also have the right to object to the processing of your personal information. You can
make such a request by contacting us by using the contact details provided in the section
‘How Can You Contact Us About This Notice?’
We will consider and act upon any request in accordance with applicable data protection
laws.
If you are located in the EEA or UK and you believe we are unlawfully processing your
information, you also have the right to complain to your local data protection supervisory
authority. You can find their contact details here:
https://ec.europa.ue/justice/data-protection/bodies/authorities/index_en.html
If you are located in Switzerland, the contact details for the data protection authorities are
available here:
https://www.edoeb.admin.ch/edoeb/en/home.html
Withdrawing Your Consent
If we are relying on your consent to process your personal information, you have the right to
withdraw your consent at any time. You can withdraw your consent at any time by contacting
us by using the contact details provided in the section ‘How Can You Contact Us About This
Policy?’
However, please note that this will not affect the lawfulness of the processing before its
withdrawal nor, will it affect the processing of your personal information conducted in reliance
on lawful processing grounds other than consent.
Opting Out of Marketing and Promotional Communications
You can unsubscribe from our marketing and promotional communications at any time by
clicking on the unsubscribe link in the emails that we send, or by contacting us using the
details provided in the section ‘How Can You Contact Us About This Policy?’. You will then
be removed from the marketing lists. However, we may still communicate with you, e.g., to
send you service-related messages that are necessary for the administration and use of your
account, to respond to service requests, or for other non-marketing purposes.
Cookies and Similar Technologies
Most web browsers are set to accept to cookies by default. If you prefer, you can usually
choose to set your browser to remove cookies and to reject cookies. If you choose to
remove cookies or reject cookies, this could affect certain feature or services of our
Services. To opt out of internet-based advertising by advertisers on our Services, visit
http://www.aboutads.info/choices
If you have any questions or comments about your privacy rights, you may email us at
info@whomedia.digital.
Controls for Do-Not-Track Feature
Most web browsers and some mobile operating systems and mobile applications include a
Do-Not-Track (‘DNT’) feature or setting you can activate to signal your privacy preference
not to have data about your online browsing activities monitored and collected. At this stage,
no uniform technology standard for recognizing and implementing DNT signals has been
finalised. As such, we do not currently respond to DNT browser signals or any other
mechanism that automatically communicates your choice not to be tracked online. If a
standard for online tracking is adopted that we must follow in the future, we will inform you
about that practice in a revised version of this privacy policy.
Do We Make Updates to This Notice?
In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.
We may update this privacy notice from time to time. The updated version will be indicated
by an updated ’Revised date and the updated version will be effective as soon as it is
accessible. If we make material changes to this privacy policy, we may notify you either by
prominently posting a notice of such changes or by directly sending you a notification. We
encourage you to review this privacy policy notice frequently to be informed of how we are
protecting your information.
How Can You Contact Us About This Policy?
If you have any questions or comments about this policy, you may email us at info@whomedia.digital or by post to:
Who Media Ltd.
Studio 37,
Fruitworks Coworking,
Jewry Lane,
Canterbury,
England,
CT1 2NP
How Can You Review, Update or Delete the Data We Collect from You?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.