Privacy Policy

PRIVACY AND COOKIE POLICY
Last updated 17 March 2023

This Privacy and Cookie Policy for Media Investment Limited (doing business as MIL) (“MIL,” “we,” “us,” “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you view, access or use any website of ours that links to this privacy policy (each, a “Site”); or engage with us in other related ways, including any sales, marketing or events. Reading 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 engages with the Sites. If you still have any questions or concerns, please contact us at support@mediainvestments.com.

1. What Information Do We Collect?

Personal Information You Disclose To Us

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or engage with the Sites, when you participate in activities on the Sites, or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Sites. The personal information we collect may include the following: names, phone numbers, e-mail addresses, mailing addresses, job titles, usernames, passwords, contact preferences, contact or authentication data, billing addresses, and or debit/credit card numbers. 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

We automatically collect certain information when you visit, use, or navigate the Sites. This information does not reveal your specific identity (like your name or contact information) but 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 Sites, and other technical information. This information is primarily needed to maintain the security and operation of the Sites, 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 service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use the Sites. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity on the Sites (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).
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Sites. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• 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 Sites. For example, 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 Sites.

Information Collected From Other Sources

In order to enhance the Sites, we may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, and from other third parties. This information includes mailing addresses, job titles, e-mail addresses, phone numbers, intent data (or user behavior data), IP addresses, social media profiles, social media URLs, and custom profiles, for purposes of targeting advertising and event promotion.

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, depending on how you interact with the Sites, including:

• To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the Sites.
• To send administrative information to you. We may process your information to send you details about the Sites, 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 Sites.
• 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 user.
• To request feedback. We may process your information when necessary to request feedback and to contact you about your use of the Sites.
• To send you marketing and promotional communications. We may process the personal information you sent to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time period. For more information, see “What Are Your Privacy Rights?” below
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more.
• To protect the Sites. We may process your information as part of our efforts to keep the Sites safe and secure, including fraud monitoring and prevention.
• To identify usage trends. We may process information about how we use the Sites to better understand how they are being used so we can improve them.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. What Legal Bases Do We Rely On To Process Your Information?

If you are located in the EU or UK, this section applies to you

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 to use your personal information for a specific purpose. You can withdraw your consent at any time. To learn more, see “Withdrawing your consent” below.
• Performance of a contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you.
• Legitimate interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
  • Send users information about special offers and discounts on the Sites;
  • Develop and display personalized and relevant advertising content for our users;
  • Analyze how the Sites are used so we can improve them to engage and retain users;
  • Support our marketing activities;
  • Diagnose problems and/or prevent fraudulent activities;
  • Understand how our users use the Sites so we can improve user experience.
• 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 and 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.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission to use your personal information for a specific purpose, or in situations where your permission can be inferred. You can withdraw your consent at any time. To learn more, see “Withdrawing your consent” below.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
• For investigations and fraud detection and prevention;
• For business transactions provided certain conditions are met;
• If it is contained in a witness statement in the collection is necessary to assess, process, or settle an insurance claim;
• For identifying injured, ill, or deceased persons and communicating with next of kin;
• If we have reasonable grounds to believe an individual has been, is, or maybe a victim of financial abuse;
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
• If disclosure is required to comply with the subpoena, warrant, court order, or rules of the court relating to the production of records;
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
• If the collection is solely for journalistic, artistic, or literary purposes;
• If the information is publicly available and is specified by the regulations.

4. When And With Whom Do We Share Your Personal Information?

We may share your data with third party vendors, service providers, contractors, or agents (“third parties”) who perform services for us or on our behalf and require access to such information 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 it is proscribed by our agreement. They also commit to protect the data they hold on our behalf and to retain it for a limited period of time. The categories of third parties we may share personal information with are as follows: ad networks, website hosting service providers, testing tools, affiliate marketing programs, data analytics services, data storage service providers, government entities, order fulfillment service providers, performance monitoring tools, retargeting platforms, product engineering and design tools, and sales and marketing tools. We also may 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
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy policy. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
• Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.
• Other Users. When you share your personal information or otherwise interact with public areas of the Sites, such personal information may be viewed by all users and may be publicly made available outside the Sites in perpetuity. Similarly, other users will be able to view descriptions of your activity, communicate with you within the Sites, and view your profile.

5. What Is Our Stance On Third-Party Websites?

The Sites may link to third-party websites, online services, or mobile applications and/or contain advertisements from third parties that are not affiliated with us, and which may link to other websites, services, or applications. Accordingly, we do not make any guarantee regarding any such third parties, and we will not be liable for any loss or damage caused by the use of such third-party websites, services, or applications. The inclusion of a link towards a third-party website, service, or application does not imply an endorsement bias. We cannot guarantee the safety and privacy of data you provide to any third parties. Any data collected by third parties is not covered by this privacy policy. We are not responsible for the content or privacy and security practices and policies of any third parties, including other websites, services, or applications that may be linked to or from the Sites. You should review the policies of such third parties and contact them directly to respond to your questions.

6. Do We Use Cookies and Other Tracking Technologies?

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 are set forth in this privacy policy and in the cookie notice displayed upon your first visit to the Sites.

7. Is Your Information Transferred Internationally?

Our servers are located in the United States. If you are accessing the Sites from outside the United States, please be aware that your information may be transferred to stored and processed by us in our facilities and by those third parties with whom we may share your personal information (see “When And With Whom Do We Share Your Personal Information?” above), in the United States, and other countries.

If you are resident of the European Economic Area (EEA) or United Kingdom (UK), then these countries may not necessarily have data protection laws or other similar laws as comprehensive as those in your country. However, we will take all necessary measures to protect your personal information in accordance with this privacy policy and applicable law.

We have implemented measures to protect your personal information, including by using the European Commission’s Standard Contractual Clauses for transfers of personal information between our group companies and between us and our third-party providers. These clauses require all recipients to protect all personal information that they process originating from the EEA or UK in accordance with European data protection laws and regulations. Our Standard Contractual Clauses can be provided upon request. We have implemented similar appropriate safeguards with our third-party service providers and partners and further details can be provided upon request.

8. How Long Do We Keep Your Information?

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. Is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than one year. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9. How Do We Keep Your Information Safe?

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet their information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cyber criminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steel, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from the Sites is at your own risk. You should only access the Sites within a secure environment.

10. Do We Collect Information From Minors?

We do not knowingly solicit data from or market to children under 18 years of age. By using the Sites, you represent that you’re at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependence use of the Sites. If we learn that personal information from users less than 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 may have collected from children under age 18, please contact us at support@mediainvestments.com.

11. What Are Your Privacy Rights?

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right to request access and obtain a copy of your personal information; to request rectification or erasure; to restrict the processing of your personal information; and, 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?” below. We will consider an 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 personal 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.eu/justice/dataprotection/bodies/authorities/index_en.htm. If you are located in Switzerland, the contact details for the relevant 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, which may be express and/or implied consent depending on the applicable law, 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 Notice?” below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Cookies And Similar Technologies:

Most web browsers are set to accept 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 features of the Sites. To opt out of interest-based advertising by advertisers on the Sites, visit http://www.aboutads.info/choices. If you have questions or comments about your privacy rights, you may e-mail us at support@mediainvestments.com.

12. Controls For Do-Not-Track Features

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 finalized. 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.

13. Do California Residents Have Specific Privacy Rights?

California Civil Code section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Sites, you have the right to request removal of unwanted data that you publicly post on the Sites. To request removal of such data, please contact us using the contact information provided below and include the e-mail address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Sites, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

The California Code of Regulations defines a “resident” as every individual who is the State of California for other than a temporary or transitory purpose; and every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, IP address, email address, and account name	Yes
B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	Yes
C. Protected classification characteristics under California or federal law	Gender and date of birth	No
D. Commercial information	Transaction information, purchase history, financial details, and payment information	No
E. Biometric information	Fingerprints and voiceprints	No
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements.	Yes
G. Geolocation data	Device location	Yes
H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or cell recordings created in connection with our business activities	No
I. Professional or employment-related information	Business contact details in order to provide the Sites at a business level or job title, work history, and professional qualification if you apply for a job with us	No
J. Education information	Students records and directory information	No
K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, and individual’s preferences and characteristics	No
L. Sensitive personal information		No

We will use and retain the collected personal information as needed to provide the Sites or for one (1) year.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of receiving help through our customer support channels; participation in customer surveys or contests; and facilitation in the delivery of the Sites and to respond to your inquiries.

How do we use and share your personal information?

Media Investment Limited Collects and shares your personal information through targeting cookies, marketing cookies, beacons, pixels, and tags. More information about our data collection and sharing practices can be found in this privacy policy. You can opt out from selling or sharing of your personal information by disabling cookies and cookie preference settings and clicking on the Do Not Sell or Share My Personal Information link on our homepage. If you are using an authorized agent to exercise your right to opt out, we may deny a request if the authorized the agent does not submit proof that they have been validly authorized to act on your behalf.

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf, following the same strict privacy protection obligations mandated by the CCPA. We may use your personal information for our own business purposes, such as for undertaking internal research, for technological development and demonstration. This is not considered to be “selling” of your personal information.

Media Investment Limited has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months: Category A, Category B, Category F, Category G

The categories of third parties to whom we disclose personal information for a business or commercial purpose can be found under “When And With Whom Do We Share Your Personal Information?”

Media Investment Limited has sold or shared the following categories of personal information to third parties in the preceding twelve (12) months: Category A, Category B, Category F, Category G. The categories of third parties to whom we sold personal information are ad networks, affiliate marketing programs, data analytics services, and retargeting platforms. The categories of third parties to whom we shared personal information with are ad networks, affiliate marketing programs, data analytics services, and retargeting platforms.

Your rights with respect to your personal data

• Request to Delete: You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect the request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise of another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against the legal activities.
• Request to Know: Depending on the circumstances you have a right to know whether we collect and use your personal information; the categories of personal information that we collect; the purposes for which the collected personal information is used; whether we sell or share personal information to third parties; the categories of personal information that we sold, shared, or disclosed for a business purpose; the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose; the business or commercial purpose for collecting, selling, or sharing personal information; And the specific pieces of personal information we collected about you. In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
• Right to Non-Discrimination: We will not discriminate against you if you exercise your privacy rights.
• Right to Limit Use: We do not process consumer sensitive personal information.

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud prevention purposes. We will delete such verifying information as soon as we finish verifying you.

In addition to the above rights, you also have the right to object to the processing of your personal information; request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of your personal information; or designate an authorized agent to make a request under the CCPA on your behalf. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

To exercise these rights you can contact us by e-mail at
support@mediainvestments.com, by visiting https://www.mediainvestments.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

Our metrics for all CCPA requests received for the previous calendar year can be found here: http://www.mediainvestments.com/tenmillionormore.

14. Do Virginia Residents Have Specific Privacy Rights?

Under the Virginia Consumer Data Protection Act (VCDPA):

• “Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household
• “Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal data does not include deidentified data or publicly available information.
• “Sale of personal data” means the exchange of personal data for monetary consideration

If this definition “consumer” applies to you, we must adhere to certain rights and obligations regarding your personal data.

The information we collect, use, and disclose about you will vary depending on how you interact with Media Investment Limited and the Sites. To find out more, please review this privacy policy.

As a Virginia consumer you have the following rights with respect to your personal data: the right to be informed whether or not we are processing your personal data; the right to access your personal data; the right to correct inaccuracies in your personal data; the right to request deletion of your personal data; the right to obtain a copy of the personal data you previously shared with us; and the right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”).

Media Investment Limited sells personal data to third parties or processes personal data for targeted advertising. More information about our data collection and sharing practices can be found in this privacy policy. You can opt out from the selling of your personal data, targeted advertising, or profiling by disabling cookies in cookie preference settings. You may contact us by e-mail at support@mediainvestments.com, by visiting mediainvestments.com/contact, or by referring to the contact details at the bottom of this document. If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request. Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please e-mail us at support@mediainvestments.com. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Virginia Attorney General to submit a complaint.

15. Do We Make Updates To This Notice?

We may update this privacy policy 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 frequently to be informed of how we are protecting your information

16. How Can You Contact Us About This Notice?

If you have questions or comments about this notice, you may e-mail us at
support@mediainvestments.com or by post to:

Media Investment Limited
71-75, Shelton Street
Covent Garden
London WC2H 9JQ
United Kingdom

17. 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 and collect from you, change that information, or delete. To request to review, update, or delete your personal information, please visit: mediainvestments.com/contact.