ATP PORTAL PRIVACY NOTICE
What does this notice cover?
This notice describes how ATP Media Operations Limited (also referred to as "ATP Media", "we" or "us") will make use of your data when you subscribe to or make use of the Media Portal, Digital Archive or Stakeholder Portal (together known as the “ATP Portals”).
It also describes your data protection rights, including a right to object to some of the processing which ATP Media carries out. More information about your rights, and how to exercise them, is set out in the “What rights do I have?” section.
Summary of how we use your data
ATP Media uses your personal data to provide you with the ATP Portals, including providing you with personalised content, and to manage your relationship (and/or the relationship of your employer) with ATP Media.
Data is shared with a number of data processors, who help provide us with the ATP Portals and with analytical services. Where we process your data as part of managing the relationship with a third party such as your employer, we will share your personal data with this third party as needed.
Our privacy notice sets out more details of this processing, including details of your data protection rights such as your right to object to certain processing.
What information do we collect?
We collect and process personal data about you when you interact with the ATP Portals. This information will typically be provided directly by you, and may include information you provide on registration or as you use the ATP Portals, such as your name, address, email address, preferences and work details. The details being provided by you will be made clear in forms you complete or will be provided directly by you in volunteering information in communications or content you provide us.
What information do we generate or receive from third parties?
We may generate or collect information about you ourselves. Much of this is set out in our Cookies section below.
Sometimes, we receive information about you from third parties such as your employer where your access to the ATP Portals is provided due to your position as an employer. Such information would include your work contact details and role, and information about the type of access you should be provided. We may also obtain information about you from third party analytics providers, which we may use to help us better understand our users and send them appropriate offers and information.
How do we use this information, and what is the legal basis for this use?
We process this personal data for the following purposes:
To fulfil a contract, or take steps linked to a contract, where we contractually grant you access to the ATP Portals. This includes:
- verifying your identity;
- communicating with you; and
- providing customer services.
As required by ATP Media to conduct our business and pursue our legitimate interests, in particular:
we monitor and analyse use of the ATP Portals and use your information to help us monitor, improve and protect our content, services and websites ;
we use information you provide to personalise the ATP Portals;
we use your data to help us manage our relationships with our suppliers and partners, and those who we supply, where this is needed to allow us to manage communications, market our product and services or otherwise administer our business;
we use information you provide to investigate any complaints received from you or from others, about our website or our products or services; and
we will use data in connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure of such information in connection with legal process or litigation).
Where you give us consent:
we place cookies and use similar technologies in accordance with our Cookies Policy and the information provided to you when those technologies are used; and
on other occasions where we ask you for consent, we will use the data for the purpose which we explain at that time;
For purposes which are required by law we will provide data in response to requests by government or law enforcement authorities conducting an investigation.
Relying on our legitimate interests
We have carried out balancing tests for all the data processing we carry out on the basis of our legitimate interests, which we have described above. You can obtain information on any of our balancing tests by contacting us using the details set out later in this notice.
Withdrawing consent or otherwise objecting to direct marketing
Wherever we rely on your consent, you will always be able to withdraw that consent, although we may have other legal grounds for processing your data for other purposes, such as those set out above. In some cases, we are able to send you direct marketing without your consent, where we rely on our legitimate interests. You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. You can do this by following the instructions in the communication where this is an electronic message, or by contacting us using the details set out below.
What cookies and/or tracking technologies does ATP Media use?
When you visit the ATP Portals we may also collect, process and use information about you and your use of the relevant Portal and how you arrived at our site. Such information may be collected through "traffic data" and may entail the use of "cookies" or other tracking technologies, IP Addresses or other numeric codes used to identify your computer. For more information on Cookies please click on the link to our Cookies Policy.
Who will we share this data with, where and when?
Where we process your data as part of the management and administration of our relationship with a third party, such as your employer, we will share your information with that third party.
Personal data may be shared with government authorities and/or law enforcement officials if required for the purposes above, if mandated by law or if required for the legal protection of our legitimate interests in compliance with applicable laws.
Personal data will also be shared with third party service providers, who will process it on behalf of ATP Media for the purposes identified above. In particular, we use third party providers of website design and hosting and video delivery services. We also use third party analytical tools, which process your data to help us get better insights into our users and allow us to improve our services and promotions.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
Some of our suppliers are located in the United States or in other countries outside the UK or EEA. Where information is transferred outside the UK or EEA, and where this is to a stakeholder or vendor in a country that is not subject to an adequacy decision, data is adequately protected by approved standard contractual clauses, an appropriate Privacy Shield certification or a vendor's Processor Binding Corporate Rules. A copy of the relevant mechanism can be provided for your review on request using the contact details set out below.
What rights do I have?
You have the right to ask us for a copy of your personal data; to correct, delete or restrict (stop any active) processing of your personal data; and to obtain the personal data you provide to us for a contract or with your consent in a structured, machine readable format, and to ask us to share (port) this data to another controller.
In addition, you can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing).
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in local laws, such as the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us – or our data protection officer – using the details set out below. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
We indicate which data is mandatory when you first sign up for the service. If this information is not provided, we cannot provide our services. Other information is optional, such as details of your preferences, but if you do not provide this when we may not be able to provide you a fully personalised service.
How do I get in touch with you?
We hope that we can satisfy queries you may have about the way we process your data. If you have any concerns about how we process your data, or would like to opt out of direct marketing, you can get in touch at firstname.lastname@example.org or by writing to ATP Media, Thames House, Portsmouth Road, Esher, Surrey, KT10 9AD. Don't forget that you can also change your preferences by visiting the logged in sections of our website.
How long will you retain my data?
Where we process registration data, or otherwise in connection with performing a contract , we do this for as long as you are an active user of our sites the ATP Portals and for at least 6 years after this. Where we process your data in relation to your relationship with a partner or supplier of ATP Media, or where this is relevant to our relationship with those we supply, we will keep this information for as long as you are involved in your relationship and for at least 6 years after this. We will hold information relating to your contact and communications with ATP Media for the same period. Where we hold this information for legal reasons, such as maintaining appropriate accounting records, we will hold the data for as long as is required by law.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). Where you have not opened an email from us in two years, we will take you off our mailing lists. We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data indefinitely so that we can respect your request in future.