This webpage sets out when and how we use your Personal Information that you or others provide to us. Your privacy is of the utmost importance to us. We want to make sure you fully understand the terms and conditions surrounding the capture and use of that information. This Privacy Notice describes what information we collect about you directly or via third parties, how we use it, and the rights you have in relation to that collection and usage.
By “Personal Information” we refer to information collected or held by Koju Media, that identifies and relates to you as an individual.
Who we are:
KOJU MEDIA LIMITED is a limited company incorporated and registered in England and Wales with the company number 10717108 whose registered office is at 164 Bury New Road, Manchester, England, M45 6AD (“Koju Media”).
For the purposes of the Data Protection Act 1998, the General Data Protection Regulations and any other applicable data protection and privacy laws and regulations (“Data Protection Legislation”), Koju Media will be the ‘data controller’ for all Personal Information we determine the means and purpose of processing and has registered with the Information Commissioners Office under registration number ZA247165
Information we collect and use at Koju Media
We gather and use Personal Information in the following circumstances.
When you register with us as a customer
When you become a Koju Media client we will collect the information required to set up a Koju Media account including your name, email address, work (and if required) home telephone number, business address and details, your role within the business that contracts Koju Media and additional information we need to identify what services you will require from us.
We will also need to collect payment and invoice information to collect fees for our.
We may collect additional information you volunteer to us when calling our support staff regarding any elements of our services. We will only retain the Personal Information pertinent to delivering your services.
We require of all this information to process the contract you have asked us to perform for you.
When you express an interest in our services
If we rely on the legitimate interest of our business as the legal grounds to process your information for marketing purposes, we will always notify you of this and your right to object to this processing. Please see “Your right to object” below. All of our marketing communications will always contain clear instructions on how to unsubscribe from future communications.
The information we request via the contact form on our “Contact Us” web page is processed specifically to provide you with the services you have requested or respond to your enquiry appropriately.
When you use our website
When people visit our webpages, we use Google analytics to collect standard internet log information (please see the “Cookies” section below) and details of visitor’s behaviour patterns. We do this to help identify the number of visitors to the site and the pages they visit. We may also collect technical information about you when you visit the Website. This information may include the Internet protocol (IP) address used to connect your computer to the Internet, your browser type and version, time zone setting, operating system and platform, browser plug-in types and version, the full URL clickstream to, through and from the Website, page response times, download errors, length of visits to certain pages, page interaction (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page.
This information is stored and used for aggregated and statistical reporting. The collected information is used to provide an overview of how people are accessing and using the .
When you phone us
When you phone us, we may also handle your Personal Information (your name, contact details and the other details you provide to us during the call) in order to service your enquiry or provide the customer services you have asked us to perform.
If you fail to provide us with Personal Information
You always reserve the right to withhold your Personal Information, but this may affect how we provide our services.
Where we need to collect Personal Information by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a service you have with us but we will notify you if this is the case at the time.
Lawful basis of processing
We will only process your information for as long as we have a relevant legal basis to do so. This is usually in order to provide you with the services you have requested from Koju Media and unless stated, all of the above processing is conducted under the legal basis of performance of a contract.
We will only use your Personal Information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we consider the new purpose to be incompatible with the original purpose of collection, we will conduct a Privacy Impact Assessment or contact you to request your consent for further processing. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us at email@example.com
A cookie is a small data file that certain websites write to your hard drive when you visit them. The only Personal Information a cookie can obtain is information supplied by the user. A cookie cannot read data from your hard disk or read cookie files created by other sites.
We use the following cookies:
- Strictly necessary cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.
- Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our website when they are using it. This helps us to improve the way our website works, for example, by ensuring that users are finding what they are looking for easily.
- Functionality cookies. These are used to recognise you when you return to our website. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to our website, the pages you have visited and the links you have followed. We will use this information to make our website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
|Google Analytics||various||Performance||These cookies are used to collect information about how visitors use our site. We use the information to compile reports and to help us improve the site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited. Click here for an overview of privacy at Google|
Protecting your information
We take our security obligations very seriously and constantly monitor for breaches and potential weaknesses.
Koju Media is committed to ensuring that data is stored, archived or disposed of in a safe and secure manner. We have procedures in place to try and prevent any unauthorised access or disclosures and to safeguard and keep secure the information that we collect.
We use computer safeguards such as firewalls and data encryption, we enforce physical access controls to our buildings and files, and we authorise access to Personal Information only for those employees who require it to fulfil their job responsibilities. We hold the Cyber Essentials security certification.
However, you should be aware that providing information over the internet can never be guaranteed as being completely safe and if you choose to send such information to us via the internet, you do so at your own risk.
Transfer of data outside of the EU
We shall not transfer any Personal Information to any country outside of the European Economic Area unless we ensure that such Personal Information is subject to an adequate level of protection and appropriate legal safeguards in accordance with Data Protection Legislation. If you wish to access your Personal Information, we will inform you of the transfers we make (if any) and the legal safeguards we have employed to ensure the ongoing security and protection of your data.
Sharing your information with others
If and when we share your data, we always do so under a written agreement governing how your data must be protected.
Please be assured that we will not share your information for any other reason unless we are required by law or permitted to do so under this Privacy Notice. The main circumstances in which we will be permitted or required to disclose this is by law will be by court order, to government bodies and law enforcement agencies. However, sometimes we may share your information with third parties in the following ways:
- we may use carefully selected sub-processors to help us collect, store or manage your information. This will always be managed under the terms of a written data processing agreement;
- analytics and search engine providers that assist us in the improvement and optimisation of the Website; and
- if Koju Media is acquired by a third party, in which case Personal Information held by it about its customers will be one of the transferred assets. We process your Personal Information for this purpose because we have a legitimate interest to ensure our business can be continued by the buyer. If you object to our use of your Personal Information in this way, the relevant seller or buyer of our business may not be able to provide services to you.
Retaining your Personal Information
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorised use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Your right to object
You have the right to object to us handling your Personal Information when:
- we are handling your Personal Information based on our legitimate interests. If you ask us to stop handling your Personal Information in this way, we will stop unless we can show you that we have compelling grounds as to why our use of your Personal Information should continue; and
- where we use your Personal Information for marketing purposes. If you ask us to stop handling your Personal Information on this basis, we will stop.
Your rights under data protection law
You can exercise the following rights to your data by contacting us at firstname.lastname@example.org We will only take instructions from you or your legal representative to effect or to alter a policy and we will protect your privacy when you contact us by asking specific and relevant questions to make sure we are speaking to you or your legal representative and not to an unauthorised person.
Right of access
You are entitled to receive confirmation as to whether your Personal Information is being processed by us, as well as various other information relating to our use of your Personal Information. You also have the right to a copy of the Personal Information which we are handling regarding you.
Right to rectification
You have the right to require us to rectify any inaccurate Personal Information we hold about you. You also have the right to have incomplete Personal Information we hold about you completed, by providing a supplementary statement to us.
Right to restriction
You can restrict our processing of your Personal Information where:
- you think we hold inaccurate Personal Information about you;
- our handling of your Personal Information breaks the law, but you do not want us to delete it;
- we no longer need to process your Personal Information, but you want us to keep it for legal reasons; or
- we are handling your Personal Information because we have a legitimate interest you and are in the process of objecting to this use of your Personal Information.
Where you exercise your right to restrict us from using your Personal Information, we will then only process your Personal Information when you agree, except for storage purposes and to handle legal claims.
Right to data portability
You have the right to receive the Personal Information we hold about you in a structured, standard machine readable format and to send this to another organisation controlling your Personal Information.
Right to erasure
You have the right to require us to erase your Personal Information which we are handling in the following circumstances:
- we no longer need to use your Personal Information for the reasons we told you we collected it for;
- where we needed your consent to use your Personal Information and you have withdrawn your consent;
- you object to our use of your Personal Information and we have no compelling reason to carry on handling your Personal Information;
- our handling of your Personal Information has broken the law; or
- we must erase your Personal Information to comply with a law we are subject to.
Right to withdraw consent
In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your Personal Information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time.
To withdraw your consent, please contact email@example.com Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law.
Right to complain
You have the right to issue a complaint directly with the Information Commissioners Office, the data protection supervisory authority for England and Wales (https://ico.org.uk/concerns/).
Changes to this Privacy Notice
We may change this Privacy Notice at any time to ensure that it always accurately reflects the way we collect, use and safeguard your Personal Information.
Please check this notice from time to time to ensure you are aware of any updates we may have made to our Personal Information handling practices. The date of the changes will be listed in the ‘Last updated’ section below. We will endeavour to notify all of our current clients of any updates to this notice via email and we will post the relevant announcement on our website homepage.
We recommend that you print a copy of this page for your reference.
Please contact us at firstname.lastname@example.org if you have any questions, comments or requests regarding this Privacy Notice.
Last updated May 2018