SFS Media Ltd Privacy Notice

 

SFS Media Ltd. (We) are committed to protecting and respecting your privacy. We don't hide behind small print because we understand how important your privacy is to you.

 

1. Your Privacy

We take your privacy seriously. You trust us with your privacy and maintaining this trust is central to everything we do. That's why we are open and transparent about what we do with your personal information.

 

SFS Media Ltd uses your personal data to provide you with a better customer experience. We want to ensure the information we send to you reflects your personal preferences.

 

1. Who are we?

We are SFS Media. Our principal address is SFS Media, 71-75 Shelton Street, Covent Garden, London, United Kingdom, WC2H 9JQ.

 

We may update this privacy notice from time to time. When we do, we will let you know by changing the date on this notice and notifying you of significant changes. By continuing to access or use our services after those changes become effective, you agree to be bound by the revised privacy notice.

 

1. What data do we collect?

Personal data (or personal information) is any information about an individual from which that person can be identified. Personal data does not include data where the identity has been removed.  This is called anonymous data.

 

We collect your personal information:
 

• directly from you when you provide it to us.

• directly from publicly available sources.

• automatically as you navigate through the Website; and

• from third parties, for example, Speakers for Schools (the parent company of SFS Media Ltd), only where you give consent to share.

 

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data includes first name, last name, username or similar identifier, title, date of birth or age, gender, photographic images, and images in video format.

• Contact Data includes residential geographical area, business address, email address and telephone numbers, any business dealings and operations, and a record of the communications and meetings you’ve had with SFS Media Ltd;

• Financial Data includes bank account and payment card details of businesses and organisations when providing services to them.

• Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

• Profile Data includes your username and password, address, ethnicity, your interests, preferences, occupation, feedback and survey responses.

• Usage Data includes information about how you use our website, products and services, by which you may be pseudonymously identified, including the values of web cookies and mobile device identifiers.

• Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated (anonymous) Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature.

However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice.

 

3.1 Special Category Data

As a young person signing up to use our service, with your specific consent, we collect and process a type of data referred to as Special Category data, in this instance it is your Ethnicity or Special Educational Need, Disability (SEND) status. We are all about inclusion, so we will use this information to ensure we are advancing social mobility across the UK.  Only anonymous special category data is shared with third parties, never information that could directly or indirectly identify you as an individual.

 

 

4.The legal basis for the processing of data

Data protection legislation governs how we can collect, process and store your data. They give you specific privacy rights in relation your data, and to electronic communications.

 

a) Our Legitimate Interest
Where we have an existing relationship with customers who have purchased services from us and we wish to communicate related services available we will use ‘soft opt-in’. This is based on the legitimate interest of SFS Media to maintain a relationship with individuals who expressed a clear interest in one of our services.  You can opt-out of these communications at any time.

We will only use the contact information we have obtained over the course of our customer relationship with you.

We may also contact you with surveys to help us understand your relationship with our services better and aid us to improve our user experiences.

 

b) Consent

You grant us your consent to collect, process, and store your data as described in this privacy policy when you sign up to use our service.

 

If you are a young person then we will always get your consent to send you marketing information. 

 

You can easily withdraw consent or opt-out from our messages. You can do this by clicking the 'unsubscribe' link at the bottom of marketing emails, or by contacting our Data Privacy & Compliance Officer. Contact details are at the bottom of this Privacy Notice. 

 

c) Contract

For higher education, careers & commercial clients, we will rely on contract for the processing of the data.  We will use the data to process your quotes; carry out financial and business checks; to create legal contracts; and to make payments for the goods, works and services that we offer. With data collected for this, we intend to keep your data for seven years after the end of the financial year in which the records were created. 

 

1. How we secure your information

We use appropriate security measures to protect the security of your personal information both online and offline. These measures vary based on the sensitivity of the personal information we collect, process and store and the current state of technology. We also take measures to ensure service providers that process personal data on our behalf also have appropriate security controls in place.

 

1. Who do we share your information with?

With your consent we share your data with Speakers for Schools, which we are wholly owned by.  Please find a link to their privacy notice - https://speakersforschools.port.im/.

 

There are times when we use third party processors (including, but not limited to, Bloomreach Exponea, DotDigital, Meta and Mailchimp) to process your personal data on our behalf for marketing purposes, including sending out marketing material.

 

Third-party service providers (processors) are not allowed to use your personal data for any other purposes than those instructed by SFS Media.

 

You should check the privacy policies of the relevant third parties mentioned above (available on their websites) in order to fully understand how they will process your data.

We will share anonymised or aggregated data, we will never share personally identifiable information with third parties.

 

1. International Data Transfers

Some recipients of your personal information, such as third party processors, are located outside of the UK or have offices in countries where data protection laws may provide a different level of protection than the laws in the UK. When transferring personal data to such recipients, we provide appropriate safeguards. We make sure that they try to look after your data as much as we do.  But unfortunately, we cannot promise that they will.

 

1. Security and Protection.

We are committed to ensuring that your information is secure. In order to prevent unauthorised access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure the information we collect online.

 

1. How long we keep your information

We will only keep your information for two years from the last interaction as long as is reasonably required for the purposes for which it was submitted or otherwise as determined by law or regulation. Once we no longer need your information it will be securely and confidentially destroyed.

 

Information relating to financial data, it will be kept for seven years after the end of the financial year in which the records were created. 

 

1. Automated Decision Making

We use technologies that are considered automated decision making or profiling to make automated decisions based on personal information we have about you. This helps us to ensure that our decision-making is as efficient as possible and you receive information most relevant to you. For example, our systems automatically determine your eligibility to claim rewards/discounts/entitlements and eligibility to enter competitions based on factors such as, but not limited to, previous placements, your location, your age, ethnicity, and gender.

 

We will not make any automated decisions about you that would significantly affect you unless such a decision is necessary for entering into, or the performance of, a contract with you, we have obtained your consent, or we are required by the applicable law to use such technology. You will find information on your right to object to this processing of your data below under Your rights as a data subject.

 

1. Your rights

Personal Information is just that - it's personal, and it's yours. So we want to make sure that it's easy for you to take control of it and exercise your legal rights.

If you make a rights request, we'll confirm that we have received your request and let you know if we need anything else from you. We must fulfil your request within one month unless the request is particularly complex or we receive multiple requests from you. In these cases we may extend the time period by up to two months, however we will only do this when we absolutely have to, and will always let you know.

 

a) Request Access to your data

This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

 

b) Request correction of the personal data that we hold about you

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;

 

c) Request deletion of your personal data

This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

 

If we have asked for your consent in order to process your personal data you can withdraw this consent in whole or part at any time.

 

d) Object to processing of your personal data

Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your situation which makes you want to object to processing on this ground as you feel it impacts your fundamental rights and freedoms. You also have the right to object to processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;

 

If we have asked for your consent in order to process your personal data you can withdraw this consent in whole or part at any time.

 

e) Restriction of processing of your personal data

Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

• if you want us to establish the data's accuracy;

• where our use of the data is unlawful but you do not want us to erase it;

• where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or

• you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;

 

f) Request transfer of your personal data

Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

 

g) Withdraw consent

Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent or on another lawful basis. If you wish to exercise any of the rights set out above, please contact us.

 

1. Complaints

We have appointed a Data Privacy & Compliance Officer who is responsible for overseeing how we treat your personal information. If you have any questions about this privacy notice, please contact our Data Privacy & Compliance Officer using the details set out below:

Name: Victoria Rowntree

Email address: dpo@sfsmedia.co.uk

 

 

If you are unhappy with the way we have processed your personal data you have the right to complain to the Information Commissioner’s Office (ICO), but we ask that you raise the issue with our Data Privacy & Compliance Officer first.

 

For information about reporting a concern to the ICO see their website - Home | ICO

 

 

 

Version 1.

 

This version of the privacy notice was created on 04/03/2022.