PRIVACY NOTICE

We collect and process information about you in order to improve your experience and what we have to offer. Please read this privacy notice carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities in the event you have a complaint.

Who we are

We collect, use, and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation and we are responsible as the data controller of that personal information for the purposes of those laws.

This privacy notice applies however you provide personal information to us, whether you go online to our websites, purchase services or goods from us or whether you telephone, email or write to us.

What personal data do we collect and use?

In the course of our relationship with you we may collect the following personal information:

• Information that you provide to us for the purpose of subscribing to our mailing lists or email notifications (including your name and email address)
• Information relating to any purchase you make on our websites (including your name, postal address including billing and delivery address, telephone numbers, email address, payment details and product information
• Notes on any purchases, orders or agreements that you make with us
• Information about your interests
• Your correspondence and communications with us

This list is not exhaustive and in specific instances, we may need to collect additional data for the purposes set out in this Privacy Notice.

Whether information has to be provided by you and why

The provision of your contact details is required from you to enable us to make subscriptions or agreements with you.

By registering with us via our website or by letter, e mail or telephone we will keep you informed of information about our websites, goods and services that we think will be of interest.

Legal basis for collect and using your personal information

We hold your personal information if you have placed an order on our website or by telephone, or subscribed to our mailing list online, or contacted us in anyway with a view to entering into a relationship with us.

We are required to set out the legal basis for collecting and processing your personal information. We collect and use your personal information:

1. as necessary to perform our contract with you:
• for the purposes of complying with our duties and exercising our rights under a contract for the sale of goods or services to you or providing you with a subscription and access to our websites; or
2. as necessary for the pursuit of our legitimate interests, including:
• selling and supplying goods and services to you;
• promoting, marketing and advertising our products and services;
• sending promotional communications which are relevant and tailored to individual customers
• protecting customers, employees and other individuals and maintaining their safety, health and welfare;
• good governance, accounting and managing and auditing our operations and complying with our legal and regulatory obligations;
• preventing, investigating and detecting crime, fraud or anti-social behaviour and prosecuting offenders, including working with law enforcement agencies;
• handling customer contacts, queries and complaints;
• protecting us, our employees and customers, by taking appropriate legal action against third parties who have committed criminal acts or are in breach of legal obligations to us;
• handling any legal claims or regulatory enforcement actions taken against us; and
3. as necessary for complying with our legal obligations including:
• where you exercise your rights under data protection laws
• for compliance with legal and regulatory requirements;
• to establish or defend legal rights; or
4. based on your consent for example in relation to sending direct marketing communications via email.

You have the right to withdraw consent at any time. Where consent is the only legal basis for processing, we will cease to process your personal information after consent is withdrawn.

How we use your personal information

We (and trusted partners acting on our behalf) use your personal information for the following purposes:

• For customer support - we may need to refer to your personal information to assist with any enquiries you have about an order with us
• Fulfilment of an order/subscription - your details may be passed to our delivery partners to facilitate an efficient delivery service
• Record-keeping including actual orders/subscriptions placed and to decide our next actions
• To contact you if we consider that new or alternative services we provide are likely to be of interest or relevant to you.

Who we share your personal information with

• We store your personal information through our Customer Relationship Management (CRM) platform. It is our internal system and the personal information is generally held within the European Economic Area and where it is not it is dealt with in accordance with the section “International transfers of your personal information” below.
• Your personal information may, for the purposes detailed in this privacy notice, be disclosed to the following third-party contractors – our web administrators, our customer service contractors, payment processing companies to allow you to pay for subscriptions, goods and services.

We only select third party contractors with a strong commitment to privacy and security standards.

We will also share your information when we are obliged to do so under applicable laws or by order of any competent authority.

We never sell or rent our customer's personal information to other organisations for any purpose.

International transfers of your personal information

To deliver products and services to you, it is sometimes necessary to share your personal information outside of the European Economic Area (the EEA). This will typically occur when service providers are located outside the EEA or if you are based outside the EEA. These transfers are subject to special rules under data protection laws.

If we transfer your personal information outside the EEA, we will ensure that the transfer will be compliant with data protection law. This will include having a lawful basis for transferring personal information and putting appropriate safeguards in place to ensure an adequate level of protection for the personal information

Information collected from Cookies & Similar Technologies

We use cookies (small text files placed on your device) and similar technologies to provide our websites and online services and to help collect data. Among other things cookies allow us to store your preferences and settings; enable you to sign-in; provide interest-based advertising; help to combat fraud; and analyse how our websites and online services are performing.

You have a variety of tools to control cookies, web beacons and similar technologies, including browser controls to block and delete cookies and controls from some third-party analytics service providers to opt out of data collection through web beacons and similar technologies. Your browser and other choices may impact your experiences with our products.

How long your personal information will be kept

• At a minimum, we will hold your personal information for a period of 7 years, as is required by current tax law (6 years plus the current year).
• Our maximum retention period is normally ten years from the date of registration.

Your rights in respect of your personal information

Under the General Data Protection Regulation you have important rights relating to updating, rectifying and deleting your personal information held with us. In summary, these include rights to:

• the right to be informed about our processing or your personal data which is the aim of this Privacy Notice;
• the right to request access to personal data we hold about you at any time;
• the right to ask us to update and correct any out-of-date or incorrect personal data that we hold about you;
• the right to object to processing of your personal data and/ or to withdraw any consent you have given us and to opt out of any marketing communications that we may send you;
• the right to prevent processing that is likely to cause damage or distress to you or anyone else;
• the right to request that we erase your personal data in certain circumstances (the right to be forgotten) or to restrict the process of your data rather than having it erased;
• if we rely on your consent as our legal basis for processing your personal information you have the right to withdraw that consent at any time

If you would like to unsubscribe from our mailing list you can do this at any time.

If you wish to exercise any of the above rights, you can always contact us either by email to [email protected] or by post to Foxy Media BV, Prinseneiland 79N, Amsterdam, 1013LM, Netherlands

For further information on each of those rights, including the circumstances in which they apply, please see the Guidance by Netherlands Data Protection Authority on individuals' rights under the General Data Protection Regulation.

Keeping your personal information secure

We have appropriate security measures in place to prevent personal information from being used or accessed in an unauthorised way or accidentally lost. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

We have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

Changes to this privacy notice

This privacy notice was published in May 2018. We may change this privacy notice from time to time. When we do, we will inform you by posting the updated version at /account/privacy.

How to contact us

Please contact us if you have any questions about this privacy notice or the personal information we hold about you. If you wish to contact us, please send an email to [email protected] or write to Foxy Media BV, Prinseneiland 79N, Amsterdam, 1013LM, Netherlands.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. If we cannot the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority. The supervisory authority in the Netherlands is the "Data Protection Authority". You have the right to lodge a complaint with the "Data Protection Authority" if you believe we have not handled your personal data in accordance with the law. Further information, including contact details, is available at https://autoriteitpersoonsgegevens.nl/nl.