Privacy Policy

Our mission is to transform the world’s video advertising workflow by automating processes and connecting people. Central to this mission is our commitment to be transparent about the data we collect about you, how it is used and with whom it is shared.

This Privacy Policy applies in conjunction with our Cookie Policy when you use our Services (defined below) or visit any of our Websites (defined below). We only collect the information we require to provide our Services to you or to enable you to access and use certain functions on our Websites. We do not share your information with third parties for marketing purposes.

Our Websites may contain links to other websites. Please note that we have no control over how your data is collected, stored or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

Introduction

IMD Media Ltd, its subsidiaries and licensees (“IMD”/“we”/”us”) offer a cloud-based service for the workflow management and delivery of digital video advertising.

Our registered users (“Users”) share their name, email address and geographic location with the other users of our Services in order to enable collaboration. We use the information you provide, or which is provided to us to manage your access whilst using our Services and/or visting our Websites. We use others to help us provide our Services and may share information with them so that they are able to do this.

What is personal data?

Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (“GDPR”) as any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier. This includes obvious information such as your name and contact details but it also includes less obvious information such as identification numbers, electronic location data and other online identifiers.

Services and Websites

This Privacy Policy applies to:

· your use of  services (“Services”)  offered by IMD Media Ltd and its subsidiaries and licensees, including Group IMD www.groupimd.com,
IMD Cloud www.imdcloud.net,
Honeycomb.tv www.honeycomb.tv,
IMD Fastrax www.fastrax.co.uk
(“Websites”);

·your visits to our Websites.

Future changes

We may modify this Privacy Policy from time to time, and if we make material changes to it, we will always aim tonotify youso that you have the opportunity to review the changes before they become effective. If you object to any changes, you may close your
account. If we are unable to notify you before the changes become effective, for example because the changes need to be made urgently to comply with a legal or regulatory obligation, we will notify you as soon as possible thereafter.

You acknowledge that your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that the collection and use of your
personal data is subject to the updated Privacy Policy. We would recommend that you check this page regularly to make sure that you have seen the latest version of the Privacy Policy.

1. Data we collect and how we collect it

1.1 Data you provide to us

To create an account you need to provide data including
your name, email address, contact phone number, city, the company you work for
and a password.

1.2 Posting and uploading

We collect personal data from you when you provide, post or
upload it to our Services and/or our Websites, such as when you fill out a form
(e.g. contact us forms) or when you submit a resume.

1.3 Service use

We log usage data when our
Websites to access the Services, such as when you view or click on content
(e.g., video), or perform a search. We use log-ins, cookies, device information
and internet protocol (“IP”) addresses to identify you and log your use.

1.4 Cookies, identifiers and other similar technologies

As further described in our Cookie Policy , we use
cookies and similar technologies (e.g., browser identifiers) to recognize you.
We also allow some others to use cookies as described in our Cookie Policy. You
can control cookies through your browser settings and other tools. You can also
opt-out from our use of cookies by following instructions in our Cookie Policy.

1.5 Your device and location

When you visit or leave our Services (including our
plugins or cookies or similar technology on the sites of others), we receive the
URL of both the site you came from and the one you go to next. We also get
information about your IP address, proxy server, operating system, web browser
and add-ons.

1.6 Messages

We collect information about you when you send, receive, or
engage with messages in connection with our Services. For example, if you use
the contact us page on our Websites or if you email our sales or support teams.

1.7 Workplace provided information

Your employer may provide us with personal data about you
and your eligibility to use the Services that they purchase for use by their
workers. For example, we will get contact information for creating your account
so that you can place an order using our Services.

1.8 Other sources of information

We may obtain your name, location and email address from a
User of our Services if they wish to connect you with an order on our Services.

1.9 Other

Our Services are dynamic, and we often introduce new
features, which may require the collection of new information. If we collect
materially different personal data or materially change how we use your data,
we will notify you and may also modify this Privacy Policy.

2. How we use your data

We use the data that we have about you to provide and
personalise our Services so that they can be more relevant and useful to you
and enable you to use our Services and/or to access and use certain functions
on our Websites.

2.1 Services

We use your data to authorise access to our Services and to
manage your account.

Our Services allow you to collaborate with colleagues or
other users of our Services and our support staff. Our Services allow you to notify
other Users of an order submission. Our Services allow you to place an order
and upload content for onward distribution to broadcasters globally.

2.2 Communications

We may use the personal data you provide to communicate
with you. This may include responding to emails or calls from you. We will send
you messages about the availability of our Services, security, features, or
other service-related issues. We also send messages about how to use the
Services, updates, and reminders .

We also enable communications between you and others
through our Services, including for example order submissions between our
Users.

2.3 Marketing

With your permission and/or where permitted by law, we may also use your
personal data for our marketing purposes, which may include contacting you by
[email]  and/or [text message] and/or [telephone] and/or post with information
news and offers on our Services or services similar to the Services. You will
not be sent any unlawful marketing or spam and you will always have the
opportunity to opt out. You can opt out at any time by contacting us at dataprotection@groupimd.com
or by updating your preferences.

We use data, including your feedback, to further
develop our Services in order to provide our Users with a better, richer
experience when using our Services.

2.5 Customer support

We use data (which can include your communications via our
online chat, telephone and email) needed to investigate, respond to and resolve
any queries you may have with our Services as well as to identify Service
issues (e.g., bugs, exceptions).

2.6 Security and investigations

We use your data (including your communications) if we
think it’s necessary to replicate and/or investigate possible problems with our
services as well as other violations of our Terms or this Privacy Policy and/or
attempts to harm our Users and/or our Services.

3. How we share information

3.1 Marketing

We do not share your personal
data with any third parties for marketing purposes.

3.2 Service providers

We use third partiesto provide our Services (e.g. maintenance,
analysis, audit, payments, hosting, marketing). They will have access to your
information as reasonably necessary to preform these tasks on our behalf and
are obligated to not disclose or use it for other purposes. We will take steps
to ensure that your personal data is handled safely, securely and in accordance
with your rights, our obligations and the third  parties’ obligations under the
law. If any personal data is transferred outside of the EEA, we will take
suitable steps in order to ensure that your personal data is treated just as
safely and securely as it would be within the UK and under the GDPR.

3.3 Change in control or sale of our business

We can also share your personal data as part of a sale,
merger or change in control, or in preparation for any of these events. Any other
entity which buys us or part of our business will have the right to continue to
use your data, but only in accordance with this Privacy Policy unless you agree
otherwise.

3.4 Legal disclosure

It is possible that we will need to
disclose information about you when required by law, or other legal process or
if we have a good faith belief that disclosure is reasonably necessary to (1)
investigate, prevent, or take action regarding suspected or actual illegal
activities or to assist government enforcement agencies; (2) enforce our
agreements with you, (3) investigate and defend ourselves against any
third-party claims or allegations, (4) protect the security or integrity of our
Service (such as by sharing with companies facing similar threats); or (5)
exercise or protect the rights and safety of IMD Media Ltd, our Users,
personnel, or others. We attempt to notify Users about legal demands for their
personal data when appropriate in our judgment, unless prohibited by law or
court order or when the request is an emergency.

4. Your data and choices

4.1 Data retention

We retain the personal data you
provide while your account is in existence or as needed to provide you with the
Services. We will retain your information and keep your profile open until you
decide to inform us you wish to close your account. In some cases we will
retain certain information (e.g., order submissions and communications) in a
depersonalized or aggregated form to fulfil our obligations with your
current/then employer and to comply with the law.

4.2
Right to be informed about our collection and use of your personal data:
this Privacy Policy should tell
you everything you need to know but you can always contact us  at dataprotection@groupimd.com.to find out more or to ask any
questions.

4.3
Right to access your personal data: you may request a report of the
personal data we have about you. The request should be made in writing and sent
to dataprotection@groupimd.com. There
is not normally any charge for such a request unless the request is manifestly
unfounded or excessive (for example, you make repetitive requests), in which
case a fee may be charged to cover our administrative costs. We will keep you
informed of the progress of your request.

4.4
You also have the following rights. Please contact us at dataprotection@groupimd.com
if you wish to exercise any of these rights or to find out more about them.

  • Right
    to have your personal data rectified if any of your personal data held by us is
    inaccurate or incomplete. You may also amend your details under profile
    management on our Services.
  • Right to be forgotten ie the right to
    ask us to delete or otherwise dispose of any of your personal data that we
    have
  • Right
    to restrict (ie prevent) the processing of your personal data.
  • Right
    to object to us using your personal data for a particular purposes or purposes.
  • Right
    to data portability. this means that if you have provided personal data to us
    directly or we are using it with your consent or for the performance of the
    Services and that data is processed using automated means, you an ask us for a
    copy of that personal data to re-use with other supplier.

4.5 Rights relating to automated decision making and profiling: we do not use your personal data in this way. Account closure

We retain your personal data even after you have closed
your account if reasonably necessary to comply with our legal obligations
(including law enforcement requests and contracts with your employer), meet
regulatory or contractual requirements, resolve disputes, maintain security,
prevent fraud and abuse, enforce our User Agreement, or fulfil your request to
“unsubscribe” from further messages from us.

5. How and where do we store or transfer personal data

5.1 We may store or transfer some or all of your
personal data in countries that are not part of the European Economic Area
(“EEA”).  These countries may not have data protection laws that are as strong
as those in the UK and/or the EEA. This means that we will take additional
steps in order to ensure that your personal data is treated just as safely and
securely as it would be within the UK and under the GDPR as follows:

  • Where we share your data with external third  parties we will
    enter into contracts with those parties which ensure that the same levels of
    personal data protection   that would apply under the GDPR; and
  • Where we transfer your data to a third party based in the US,
    this may be protected if that third party is part of the EU-US or Swiss-US
    Privacy Shields. These require that third party to provide data protection to
    standards similar to those in the EEA.

5.2 The security of your personal data is essential to
us and to protect your data we take a number of important measures including
the following:

  • We implement security safeguards designed to protect your data,
    such as HTTPS and storing your personal data in encrypted form.
  • We regularly monitor our systems for possible vulnerabilities and
    attacks.

6. Contact information

If you have questions or complaints regarding this Privacy
Policy please first contact us by emailing dataprotection@groupimd.com.

If you feel you haven’t received a timely or satisfactory
response from us to your question or complaint, please contact the Information
Commissioner’s Office: