Privacy Policy

1. General Information
Summary

This Notice explains how we may Process your Personal Data. This Notice may be amended or updated from time to time, so please check it regularly for updates. This Notice is issued by M7 Media Network on behalf of itself, its subsidiaries and its affiliates (together, “M7 Media Network”, “we”, “us” and “our”) and is addressed to individuals outside our organisation with whom we interact, specifically customers (Customers), visitors to our Sites (Audience), users of our Apps (Audience), other users of our services (Audience), and visitors to our premises (Visitors)(together, “you”). Defined terms used in this Notice are explained in Section (R) below. For the purposes of this Notice, M7 Media Network Media Network is the Controller. Contact details are provided in Section (Q) below. This Notice may be amended or updated from time to time to reflect changes in our practices with respect to the Processing of Personal Data, or changes in applicable law. We encourage you to read this Notice carefully, and to regularly check this page to review any changes we might make in accordance with the terms of this Notice.

2. Collection of Your Personal Data
Summary

We may collect or obtain Personal Data about you: directly from you (e.g., where you contact us); in the course of our relationship with you (e.g., if you make a purchase); when you make your Personal Data public (e.g., if you make a public post about us on social media); when you download, install, or use any of our Apps; when you visit our Sites; when you register to use any of our Sites, Apps, or services; or when you interact with any third party content or advertising on a Site or in an App. We may also receive Personal Data about you from third parties (e.g., law enforcement authorities).
The following sources where we may collect Personal Data about you from:

1. Data you provide: We may obtain your Personal Data when you provide it to us (e.g., where you contact us via email or telephone, or by any other means, or when you provide us with your business card).
2. Relationship data: We may collect or obtain your Personal Data in the ordinary course of our relationship with you (e.g., if you purchase a service from us, where applicable).
3. Data you make public: We may collect or obtain your Personal Data that you manifestly choose to make public, including via social media (e.g., we may collect information from your social media profile(s), if you make a public post about us).
4. App data: We may collect or obtain your Personal Data when you download or use any of our Apps.
5. Site data: We may collect or obtain your Personal Data when you visit any of our Sites or use any features or resources available on or through a Site.
6. Registration details: We may collect or obtain your Personal Data when you use, or register to use, any of our Sites, Apps, or services.
7. Content and advertising information: If you choose to interact with any third party content or advertising on a Site or in an App, we may receive Personal Data about you from the relevant third party.
8. Third-party information: We may collect or obtain your Personal Data from third parties who provide it to us (e.g., credit reference agencies; law enforcement authorities; etc.).
3. Creation of Your Personal Data
Summary

We may create Personal Data about you (e.g., records of your interactions with us).
Where applicable, we may also create Personal Data about you, such as records of your interactions with us and details of your purchase history.

4. Categories of Personal Data we may Process
Summary

We may Process: your personal details (e.g., your name); demographic data (e.g., your age); your contact details (e.g., your address); records of your consents; purchase details; payment details (e.g., your billing address); information about our Sites and Apps (e.g., the type of device you are using); details of your employer (where relevant); information about your interactions with our content or advertising; and any views or opinions you provide to us.
We may Process the following categories of Personal Data about you:

1. Personal details: name; email; and photograph.
2. Personal documents: email, letters, diaries, notes.
3. Personal aspects:People or groups with whom you relate, Temperament, Character, Intelligence, Social roles, Adaptability, Risk tolerance, Content preferences, Habits, Personal interests.
4. Biometric data:Fingerprints.
5. Demographic information: gender; date of birth / age; nationality; salutation; title; and language preferences.
6. Unique identifiers: IP address, MAC address, IMSI, IMEI, Device ID, Phone number, social media identifier, Other unique identifier.
7. Electronic communication data: E-mails, Instant messages, Phone calls, Video calls.
8. Consent records: records of any consent you may have given, together with the date and time, means of consent and any related information (e.g., the subject matter of the consent).
9. Purchase details: records of purchases and prices.
10. Content and advertising data: records of your interactions with our online advertising and content, records of advertising and content displayed on pages or App screens displayed to you, and any interaction you may have had with such content or advertising (including mouse hover, mouse clicks, any forms you complete (including incomplete forms not submitted) and any touchscreen interactions).
11. Views and opinions: any views and opinions that you express and/or choose to send to us, or publicly post about us on social media platforms.
12. Apps and Sites data: Log of visited pages, activity date and time, visits, connections, mouse activity, browser used, device used, operating system, browser settings, App use statistics, App setting, location data, username, password, login security details.
5. Sensitive Personal Data
Summary

We do not seek to collect or otherwise Process your Sensitive Personal Data. Where we need to Process your Sensitive Personal Data for a legitimate purpose, we do so in accordance with applicable law.
We do not seek to collect or otherwise Process your Sensitive Personal Data in the ordinary course of our business. Where it becomes necessary to process your Sensitive Personal Data for any reason, we rely on one of the following legal bases:

1. Compliance with applicable law: We may Process your Sensitive Personal Data where the Processing is required or permitted by applicable law (e.g., to comply with our diversity reporting obligations, or to record and develop material for journalistic purposes);
2. Detection and prevention of crime: We may Process your Sensitive Personal Data where the Processing is necessary for the detection or prevention of crime (including the prevention of fraud);
3. Establishment, exercise or defence of legal rights:We may Process your Sensitive Personal Data where the Processing is necessary for the establishment, exercise or defence of legal rights; or
4. Consent:We may Process your Sensitive Personal Data where we have, in accordance with applicable law, obtained your prior, express consent prior to Processing your Sensitive Personal Data (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).
6. Purposes for which we may Process your Personal Data, and legal bases for such Processing
Summary

We may Process your Personal Data for the following purposes: providing Sites, Apps, and services to you; journalistic purposes; operating our business; communicating with you; managing our IT systems; health and safety; financial management; conducting surveys; ensuring the security of our premises and systems; conducting investigations where necessary; compliance with applicable law; improving our Sites, Apps, and services; fraud prevention; establishment, exercise and defence of legal claims; and recruitment and job applications.
The purposes for which we may Process Personal Data, subject to applicable law, and the legal bases on which we perform such Processing, are as follows:

Processing Purpose(s)	Legal basis	Data Subject(s)
Provision of Sites, Apps, and services: providing our Sites, Apps, or services; providing promotional items upon request; and communicating with you in relation to those Sites, Apps, or services.	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, or services; or We have obtained your prior consent to the Processing.	Customers, Audience
Account Management: creation of account, update account information, deletion of the account, password management.	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have obtained your prior consent to the Processing.	Customers, Audience, Visitors
Profiling: Creating profiles, use of profiles, classification of individuals, targeting of products/services to individuals or groups, targeting of content, behavioral analysis	We have obtained your prior consent to the Processing.	Customers, Audience
Advertisement: selecting ads, creating personalized Ads profile, select personalised Ads, Measure Ad performance,	We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, Apps, or services; or We have obtained your prior consent to the Processing.	Customers, Audience
Operating our business: operating and managing our Sites, our Apps, and our services; providing content to you; displaying advertising and other information to you; communicating and interacting with you via our Sites, our Apps, or our services; and notifying you of changes to any of our Sites, our Apps, or our services.	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of providing our Sites, our Apps, or our services to you; or · We have obtained your prior consent to the Processing.	Customers, Audience
Communications and marketing: communicating with you via any means (including via email, telephone, text message, social media, post or in person) to provide news items and other information in which you may be interested, subject always to obtaining your prior opt-in consent to the extent required under applicable law; personalising our Sites, products and services for you; maintaining and updating your contact information where appropriate; obtaining your prior, opt-in consent where required; enabling and recording your choice to opt-out or unsubscribe, where applicable.	The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us; or We have a legitimate interest in carrying out the Processing for the purpose of contacting you, subject always to compliance with applicable law; or We have obtained your prior consent to the Processing.	Customers, Audience
Management of IT systems: management and operation of our communications, IT and security systems; and audits (including security audits) and monitoring of such systems.	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of managing and maintaining our communications and IT systems (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).	Customers, Audience, Visitors
Health and safety: health and safety assessments and record keeping; providing a safe and secure environment at our premises; and compliance with related legal obligations.	· The Processing is necessary for compliance with a legal obligation; or · We have a legitimate interest in carrying out the Processing for the purpose of ensuring a safe environment at our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary to protect the vital interests of any individual.	Visitors
Financial management: sales; finance; corporate audit; and vendor management. To process payments for products, services, or subscriptions purchased by users.	We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or · We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way). The Processing is necessary in connection with any contract that you have entered into with us, or to take steps prior to entering into a contract with us;	Customers, Audience
Surveys: engaging with you for the purposes of obtaining your views on our Sites, our Apps, or our services.	We have a legitimate interest in carrying out the Processing for the purpose of conducting surveys, satisfaction reports and market research (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).	Customers, Audience, Visitors
Security: physical security of our premises (including records of visits to our premises); CCTV recordings; and electronic security (including login records and access details).	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of ensuring the physical and electronic security of our business and our premises (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).	Visitors
Investigations: detecting, investigating and preventing breaches of policy, and criminal offences, in accordance with applicable law.	The Processing is necessary for compliance with a legal obligation; or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, breaches of our policies and applicable laws (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).	Customers, Audience, Visitors
Audit and Compliance: compliance with our legal and regulatory obligations under applicable law, Statutory or Internal Audit.	The Processing is necessary for compliance with a legal obligation. We have a legitimate interest in carrying out the Processing for the purpose of auditing.	Customers, Audience, Visitors
Improving our Sites, Apps, and services: identifying issues with our Sites, our Apps, or our services; planning improvements to our Sites, our Apps, or our services; and creating new Sites, Apps, or services.	We have a legitimate interest in carrying out the Processing for the purpose of improving our Sites, our Apps, or our services (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or We have obtained your prior consent to the Processing (this legal basis is only used in relation to Processing that is entirely voluntary – it is not used for Processing that is necessary or obligatory in any way).	Customers, Audience
Fraud prevention: Detecting, preventing and investigating fraud.	The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law); or We have a legitimate interest in carrying out the Processing for the purpose of detecting, and protecting against, fraud (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms).	Customers, Audience, Visitors
Establishment, exercise and defense of legal claims: management of legal claims; establishment of facts and claims, including collection, review and production of documents, facts, evidence and witness statements; exercise and defense of legal rights and claims, including formal legal proceedings.	The Processing is necessary for compliance with a legal obligation; We have a legitimate interest in carrying out the Processing for the purpose of establishing, exercising or defending our legal rights (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms); or The Processing is necessary for the establishment, exercise or defense of legal claims.	Customers, Audience, Visitors
Content Rights Restriction: To ensure that users access content they have rights to and prevent unauthorised access.	We have a legitimate interest in carrying out the Processing for the purpose of managing and operating the financial affairs of our business (to the extent that such legitimate interest is not overridden by your interests, fundamental rights, or freedoms);	Customers, Audience, Visitors
Contests: To allow users to participate in contests, sweepstakes, or promotions and notify winners.	We have obtained your prior consent to the Processing.	Customers, Audience, Visitors
Incident and Request: To manage and resolve incidents or requests raised by users.	We have obtained your prior consent to the Processing. The Processing is necessary for compliance with a legal obligation (especially in respect of applicable employment law)	Customers, Audience, Visitors

7. Disclosure of Personal Data to third parties
Summary

We may disclose your Personal Data to: legal and regulatory authorities; our external advisors; our Processors; any party as necessary in connection with legal proceedings; any party as necessary for investigating, detecting or preventing criminal offences; any purchaser of our business; and any third party providers of advertising, plugins or content used on our Sites or our Apps.

1. legal and regulatory authorities, upon request, or for the purposes of reporting any actual or suspected breach of applicable law or regulation;
2. accountants, auditors, lawyers and other outside professional advisors to M7 Media Network, subject to binding contractual obligations of confidentiality;
3. third party Processors (such as payment services providers; shipping companies; etc.), located anywhere in the world, subject to the requirements noted below in this Section (G);
4. any relevant party, law enforcement agency or court, to the extent necessary for the establishment, exercise or defense of legal rights;
5. any relevant party for the purposes of prevention, investigation, detection or prosecution of criminal offences or the execution of criminal penalties, including safeguarding against and the prevention of threats to public security;
6. any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets (including in the event of a reorganization, dissolution or liquidation); and
7. any relevant third party provider, where our Sites and our Apps use third party advertising, plugins or content. If you choose to interact with any such advertising, plugins or content, your Personal Data may be shared with the relevant third party provider. We recommend that you review that third party’s privacy policy before interacting with its advertising, plugins or content.
8. If we engage a third-party Processor to Process your Personal Data, the Processor will be subject to binding contractual obligations to: (i) only Process the Personal Data in accordance with our prior written instructions; and (ii) use measures to protect the confidentiality and security of the Personal Data; together with any additional requirements under applicable law.
8. Profiling
Summary

The Processing of your Personal Data may include automated decision-making, including Profiling.
The Processing of your Personal Data may include automated decision-making, including Profiling, which is carried out for the following purposes:

Profiling activity	The logic of the Profiling activity	Consequences for you
Personalised Content	We may analyse your website/apps usage along with other publicly available information and third party information. This information may be used to determine the most appropriate content and/or services that may interest you.	The profiling activity may mean that you will see content differently on our site as compared to other users. We do not make any content unavailable unless required by law and/or our policy.
Geographical Content	We may use your geographical origin information. This information will be used to ensure you only see content and services available to that geographic areas.	The profiling activity may mean that you will not see some content/services. We do not make any content unavailable unless required by law and/or our policy.

9. International Transfer of Personal Data
Summary

We may transfer your Personal Data to recipients in other countries. Where we transfer Personal Data from the EEA / UK to a recipient outside the EEA / UK that is not in an Adequate Jurisdiction, we do so on the basis of appropriate transfer mechanisms.
Because of the international nature of our business, we may need to transfer your Personal Data within the M7 Media Network group, and to third parties as noted in Section (G) above, in connection with the purposes set out in this Notice. For this reason, we may transfer your Personal Data to other countries that may have different laws and data protection compliance requirements to those that apply in the country in which you are located.
If an exemption or derogation applies (e.g., where a transfer is necessary to establish, exercise or defend a legal claim) we may rely on that exemption or derogation, as appropriate. Where we transfer your Personal Data from the EEA to recipients located outside the EEA who are not in Adequate Jurisdictions, we do so on the basis of Standard Contractual Clauses. Where we transfer your Personal Data from the UK to recipients located outside the UK who are not Adequate Jurisdictions, we do so on the basis of the International Data Transfer Agreement (or the corresponding addendum to the Standard Contractual Clauses). You may request a copy of these transfer mechanisms using the contact details provided in Section (Q) below.
Please note that when you transfer any Personal Data directly to an M7 Media Network entity established outside the EEA or UK, we are not responsible for that transfer of your Personal Data. We will nevertheless Process your Personal Data, from the point at which we receive those data, in accordance with the provisions of this Notice.

10. Data security
Summary

We implement appropriate technical and organisational security measures to protect your Personal Data.
We have implemented appropriate technical and organisational security measures designed to protect your Personal Data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, unauthorised access, and other unlawful or unauthorised forms of Processing, in accordance with applicable law.
Because the internet is an open system, the transmission of information via the internet is not completely secure. Although we will implement all reasonable measures to protect your Personal Data, we cannot guarantee the security of your data transmitted to us using the internet – any such transmission is at your own risk and you are responsible for ensuring that any Personal Data that you send to us are sent securely.

11. Data accuracy
Summary

We take every reasonable step to ensure that your Personal Data are kept accurate and up-to-date
We take every reasonable step to ensure that: - your Personal Data that we Process are accurate and, where necessary, kept up to date; and
- any of your Personal Data that we Process that are inaccurate (having regard to the purposes for which they are Processed) are erased or rectified without delay.
From time to time we may ask you to confirm the accuracy of your Personal Data.

12. Data minimisation
Summary

We take every reasonable step to limit the volume of your Personal Data that we Process to what is necessary.
We take every reasonable step to ensure that your Personal Data that we Process are limited to the Personal Data reasonably necessary in connection with the purposes set out in this Notice.

13. Data retention
Summary

We take every reasonable step to ensure that your Personal Data are only retained for as long as they are needed in connection with a lawful purpose
We take every reasonable step to ensure that your Personal Data are only Processed for the minimum period necessary for the purposes set out in this Notice. The criteria for determining the duration for which we will retain your Personal Data are as follows:

1. we will retain copies of your Personal Data in a form that permits identification only for as long as:

(a) we maintain an ongoing relationship with you (e.g., where you are a user of our services, or you are lawfully included in our mailing list and have not unsubscribed); or

(b) your Personal Data are necessary in connection with the lawful purposes set out in this Notice, for which we have a valid and continuing legal basis (e.g., where your Personal Data are included in a contract between us and your employer, and we have a legitimate interest in Processing those data for the purposes of operating our business and fulfilling our obligations under that contract; or where we have a legal obligation to retain your Personal Data),

plus:

2. the duration of:

(a) any applicable limitation period under applicable law (i.e., any period during which any person could bring a legal claim against us in connection with your Personal Data, or to which your Personal Data may be relevant); and

(b) an additional two (2) month period following the end of such applicable limitation period (so that, if a person brings a claim at the end of the limitation period, we are still afforded a reasonable amount of time in which to identify any Personal Data that are relevant to that claim),

and:

3. in addition, if any relevant legal claims are brought, we may continue to Process your Personal Data for such additional periods as are necessary in connection with that claim.

During the periods noted in paragraphs (2)(a) and (2)(b) above, we will restrict our Processing of your Personal Data to storage of, and maintaining the security of, those data, except to the extent that those data need to be reviewed in connection with any legal claim, or any obligation under applicable law.
Once the periods in paragraphs (1), (2) and (3) above, each to the extent applicable, have concluded, we will either:
- permanently delete or destroy the relevant Personal Data; or - anonymize the relevant Personal Data.

14. Your legal rights
Summary

Subject to applicable law, you may have a number of rights, including: the right not to provide your Personal Data to us; the right of access to your Personal Data; the right to request rectification of inaccuracies; the right to request the erasure, or restriction of Processing, of your Personal Data; the right to object to the Processing of your Personal Data; the right to have your Personal Data transferred to another Controller; the right to withdraw consent; and the right to lodge complaints with Data Protection Authorities. We may require proof of your identity before we can give effect to these rights.
Subject to applicable law, you may have a number of rights regarding the Processing of your Relevant Personal Data, including:

• the right not to provide your Personal Data to us (however, please note that we may be unable to provide you with the full benefit of our Sites, our Apps, or our services, if you do not provide us with your Personal Data – e.g., we may not be able to process your orders without the necessary details);
• the right to request access to, or copies of, your Relevant Personal Data, together with information regarding the nature, Processing and disclosure of those Relevant Personal Data;
• the right to request rectification of any inaccuracies in your Relevant Personal Data;
• the right to request, on legitimate grounds:
  • erasure of your Relevant Personal Data; or
  • restriction of Processing of your Relevant Personal Data;
• the right to have certain Relevant Personal Data transferred to another Controller, in a structured, commonly used and machine-readable format, to the extent applicable;
• where we Process your Relevant Personal Data on the basis of your consent, the right to withdraw that consent (noting that such withdrawal does not affect the lawfulness of any Processing performed prior to the date on which we receive notice of such withdrawal, and does not prevent the Processing of your Personal Data in reliance upon any other available legal bases); and
• the right to lodge complaints with a Data Protection Authority regarding the Processing of your Relevant Personal Data by us or on our behalf.
Subject to applicable law, you may also have the following additional rights regarding the Processing of your Relevant Personal Data:
• The right to object, on grounds relating to your particular situation, to the Processing of your Relevant Personal Data by us or on our behalf, where such processing is based on Articles 6(1)(e) (public interest) or 6(1)(f) (legitimate interests) of the GDPR; and
• The right to object to the Processing of your Relevant Personal Data by us or on our behalf for direct marketing purposes.

This does not affect your statutory rights.
To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Notice, or about our Processing of your Personal Data, please use the contact details provided in Section (Q) below. Please note that:

• we may require proof of your identity before we can give effect to these rights; and
• where your request requires the establishment of additional facts (e.g., a determination of whether any Processing is non-compliant with applicable law) we will investigate your request reasonably promptly, before deciding what action to take.
15. Cookies and similar technologies
Summary

We may Process your Personal Data by placing or reading Cookies and similar technologies. For more information, please see our Cookie Policy.
When you visit a Site or use an App we may place Cookies onto your device, or read Cookies already on your device, subject always to obtaining your consent, where required, in accordance with applicable law. We use Cookies to record information about your device, your browser and, in some cases, your preferences and browsing habits. We may Process your Personal Data through Cookies and similar technologies, in accordance with our Cookie Policy.

16. Direct marketing
Summary

We may Process your Personal Data to contact you with information regarding services that may be of interest to you. You may unsubscribe for free at any time.
We may Process your Personal Data to contact you via email, telephone, direct mail or other communication formats to provide you with information regarding services that may be of interest to you. If we provide services to you, we may send information to you regarding our services, upcoming promotions and other information that may be of interest to you, using the contact details that you have provided to us and always in compliance with applicable law.
You may unsubscribe from our promotional email list at any time by simply clicking on the unsubscribe link included in every promotional email we send. After you unsubscribe, we will not send you further promotional emails, but we may continue to contact you to the extent necessary for the purposes of any services you have requested.

17. Contact details
Summary

You may contact us by post or using our online form.
If you have any comments, questions, or concerns about any of the information in this Notice, or any other issues relating to the Processing of Personal Data carried out by us, or on our behalf, please contact:

Contacting the Data Protection Office

M7 Media Network Data Protection Officer is Imran Chowdhury, you can contact him at:
M7 Media Network
Al Dafna, Majlis Al Taawon St, Tornado Tower F16 No.12
P.O.Box 4212 Doha, Qatar

18. Definitions
• “App” means any application made available by us (including where we make such applications available via third party stores or marketplaces, or by any other means).
• “Adequate Jurisdiction” a jurisdiction that has been formally designated by the European Commission (or UK Information Commissioner’s Office) as providing an adequate level of protection for Personal Data.
• “Cookie” means a small file that is placed on your device when you visit a website (including our Sites). In this Notice, a reference to a “Cookie” includes analogous technologies such as web beacons and clear GIFs.
• “Controller” means the entity that decides how and why Personal Data are Processed. In many jurisdictions, the Controller has primary responsibility for complying with applicable data protection laws.
• “Data Protection Authority” means an independent public authority that is legally tasked with overseeing compliance with applicable data protection laws.
• “EEA” means the European Economic Area.
• “GDPR” means the General Data Protection Regulation (EU) 2016/679.
• “International Data Transfer Agreement” means the international data transfer agreement adopted by the UK Information Commissioner’s Office.
• “Personal Data” means information that is about any individual, or from which any individual is directly or indirectly identifiable, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that individual.
• “Process”, “Processing” or “Processed” means anything that is done with any Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• “Processor” means any person or entity that Processes Personal Data on behalf of the Controller (other than employees of the Controller).
• “Profiling” means any form of automated Processing of Personal Data consisting of the use of Personal Data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• “Relevant Personal Data” means Personal Data in respect of which we are the Controller. It expressly does not include Personal Data of which we are not the Controller.
• “Sensitive Personal Data” means Personal Data about race or ethnicity, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, sexual life, any actual or alleged criminal offences or penalties, national identification number, or any other information that may be deemed to be sensitive under applicable law.
• “Standard Contractual Clauses” means template transfer clauses adopted by the European Commission or adopted by a Data Protection Authority and approved by the European Commission.
• “Site” means any website operated, or maintained, by us or on our behalf.
• “UK” means the United Kingdom.

Version: v2.0
27 August 2024 Tuesday