1. INTRODUCTION

Silence Media create and place display advertising, and everything we do with personal data is connected to that purpose. We do not collect, generate, share or sell data for any purpose not connected to the service we provide to our clients.

We receive data about clients and suppliers (which may include photographers, programmers, graphic designers and actors), and the people who work for them, in the ordinary course of providing our services to clients. In most cases this is just names, contact details, job roles, and information about the project or services we are delivering. We hold bank details so that we can pay people, and we sometimes hold photographs of people who appear in the ads.

We use this personal data in order to carry out our contracts with clients and suppliers, and in accordance with our legitimate interest in providing these services to our clients. This may include sharing between creative partners some basic data about who someone is, and what their contact details are.

2. DATA USED DIRECTLY TO DELIVER THE SERVICES

Silence Media create and place display advertising, and everything we do with personal data is connected to that purpose. We do not collect, generate, share or sell data for any purpose not connected to the service we provide to our clients.

We receive data about clients and suppliers (which may include photographers, programmers, graphic designers and actors), and the people who work for them, in the ordinary course of providing our services to clients. In most cases this is just names, contact details, job roles, and information about the project or services we are delivering. We hold bank details so that we can pay people, and we sometimes hold photographs of people who appear in the ads.

We use this personal data in order to carry out our contracts with clients and suppliers, and in accordance with our legitimate interest in providing these services to our clients. This may include sharing between creative partners some basic data about who someone is, and what their contact details are.

3. MARKETING ACTIVITIES

We run a newsletter to keep people updated about what we’re doing and the services we offer, and we send this only to people who have signed up via our website at www.silence-media.com. We need a name and an email address to send these, and it is managed by a mailing company on our behalf.

We also contact potential clients in a more specific way when we think that they may be interested in our services. This is in accordance with our legitimate interest in letting people know about our services, in order to build our business. We use information provided by a lead generation company to do this. We only contact companies for this purpose, rather than individuals, and we are careful to make sure that we contact the right person in the organisation. Before calling anyone on the phone for these purposes, we check the number against the TPS and CTPS do not call lists. If anyone asks us to not contact them in this way, we stop.

4. WEBSITE ANALYTICS (COOKIES)

We use a third-party analytics company to give us information about who visits our website, in line with our legitimate interests relating to improving our websites design, improving security or fixing technical issues.

The analytics company receives certain information, including the visitors IP address, information about the device, browser and network used to view the site, information about when they visited the site and for how long, and information about which pages were viewed. We do not receive any personal data, but instead receive anonymised data to help us identify trends in who uses our website and how. [The analytics company also uses this data to serve adverts, on behalf of third-party advertisers, to people viewing our website that they think are likely to meet certain criteria].

This information is generated by using cookies. A cookie is a small, often encrypted file of letters and numbers that we store on a visitors browser, computer, mobile device or other device. For example, when someone visits our website, a cookie is placed in their browser. When they return to the site, our website reads the cookie, and knows it’s the same person. This helps us see clearer patterns about who is using the website and how.

Any internet user may change the settings on their internet browser to reject cookies. Please note that setting a browser to reject cookies, may mean that some of the features of our website become inaccessible.

If a visitor continues to use our website, we will take that as consent to the relevant cookies being stored on their computer or other device.

5. VIEWERS OF OUR ADVERTS

Silence Media does not serve adverts to internet users on the basis of real or perceived information about that user’s search history, age, location, likes, or other such information. Instead, we consider the contextual information about the websites that our ads appear in.

We need to gather information about how many times an advert has been engaged with, so that we can demonstrate effectiveness of the advertising to our clients, but we try to keep the data that we gathered to a minimum, and do not gather sufficient data to identify individuals.

Where we use a third-party company to purchase media space, they may place cookies via our adverts that they serve, and may gather personal data such as IP addresses etc, as explained above. However, we do not receive personally identifiable data back from these services, and we don’t use it to target adverts at particular users.

6. POSSIBLE FUTURE USES OF THE INFORMATION

There are some circumstances in which we might use data that we hold on clients or suppliers for other purposes. For example, if the business was being sold, or restructured, we might need to share or provide access to our advisors, or another party in that transaction, for the legitimate interests of facilitating the transaction.

We might share data in the event of a dispute. For example, if a client has not paid our bill, we might share their data with lawyers or other professionals to help us recover the debt. We also might share data if we are under a duty to disclose or share personal data in order to comply with any legal obligation, for example if the police or tax authorities request the information.

We do not use personal data as part of any automated decision-making, including profiling, which produces legal or similarly significant effects.

7. OUR PROCESSORS

Like any business in the digital field, we use third parties to provide IT services like a customer relationship management (CRM) system, document storage systems, email services and invoicing software. Many of these are cloud based, which means that they process the data that we hold.

We have reviewed the data practices of the processors that we use to make sure that they are safe, secure and in line with legal requirements.

Some of our processors store or transfer the data outside of the EU for the purpose of providing their services to us. Where this is to the US, it is generally pursuant to the EU-US Privacy Shield. Some of our processors use EU Commission approved standard contractual clauses to share data between different countries. For details of the measures used by our processors to ensure protection of personal data, please write to us at the email address in part 11 of this Notice.

8. HOW LONG WE HOLD DATA FOR

We will store personal data for as long as necessary to fulfil the purposes for which it is originally collected, as explained in this Notice, or any other lawful purpose subsequently communicated to the data subject, and for other essential purposes such as complying with legal obligations and enforcing our rights, such as those arising under any agreement with our clients. The retention period may therefore vary for different types of data, and depending on how and why it was gathered. Criteria relevant to determine retention periods include:

• If the data is necessary for the performance of a contract, we will retain it while performance under that contract remains active, and for a period thereafter in which that data may still be relevant to dispute resolution, enforcement of rights under the contract, or where additional connected contracts are likely to arise.


• If the data is processed pursuant to consent only, and consent is withdrawn, we may delete the data immediately, or we may cease processing and retain the data for a period if we have a need to keep it for dispute resolution or enforcement of rights.


• In certain cases we may be legally obliged to hold data for a certain period of time, or to delete the data at a certain time, including in accordance with the exercise of data subjects’ rights as explained in this Notice.

9. DATA SUBJECT RIGHTS

The person that data is about is called the data subject. The GDPR provides data subjects with various further rights, including the right to:

• request from us confirmation of whether or not their personal data is being processed and where that is the case, confirmation of the information set out in this Notice;


• request from us a copy of their data that is undergoing processing, including, in relation to data provided to us by a data subject, and which is processed by automatic means pursuant to a contract with them, or pursuant to their consent, a right to request that data in a structured, commonly used and machine readable format;


• request that we rectify or complete personal data, where it is inaccurate or incomplete for the purposes of our processing of the data;


• request that we cease using data for direct marketing purposes;


• request that we erase personal data in the following circumstances:
  
  
  • the personal data is no longer necessary in relation to the purposes for which it is processed;
  
  
  • consent is withdrawn and there is no other legal ground for the processing;
  
  
  • the data subject successfully object to the processing pursuant to their right of objection explained below;
  
  
  • the personal data has been unlawfully processed;
  
  
  • the erasure is necessary for compliance with a relevant legal obligation that applies to us;


• request that we restrict the processing of the personal data in the following circumstances:
  
  
  • the data subject contests the accuracy of the personal data, for a period enabling us to verify the same;
  
  
  • the processing is unlawful, but the data subject requests restriction rather than erasure;
  
  
  • we no longer need the data, but it is required by the data subject in respect of legal claims;
  
  
  • the data subject has objected to the processing, until such time that we verify that there are legitimate purposes that justify such processing;


• object to any processing that is based on our, or a third-party’s legitimate interests, upon which event we shall suspend processing until we demonstrate legitimate purposes that justify that processing. We may at all times continue to use data for the purpose of establishment, exercise or defence of legal claims;


• withdraw consent for future processing (where the processing is based on that consent);


• lodge a complaint with the Information Commissioner’s Office, which is the data protection supervisory authority in the UK.

We will comply with any valid request for information under the rights explained above within one month, though we may tell the data subject that this period is to be extended by a further two months where necessary, taking into account the complexity and number of the requests. This will normally be provided free of charge. If the request is manifestly unfounded, excessive or repetitive we may charge a reasonable fee or refuse to action the request.

The provision of personal data to us is not a statutory requirement nor is it normally a contractual requirement.

Our Platform may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates (including, but not limited to, websites on which our Platform is advertised). Please note that these websites and any services that may be accessible through them have their own privacy notices and that we do not accept any responsibility or liability for these notices or for any personal data that may be collected through these websites or services. Please check these notices before submitting any personal data to these websites or use these services.

10. CHANGES TO OUR PRIVACY NOTICE

Any changes we may make to our Privacy Notice in the future will be posted on this page of our website. Please check back frequently to see any updates or changes to our Privacy Notice.

11. CONTACT

Questions, comments and requests regarding this Privacy Notice are welcomed and should be addressed to Lee Henshaw at lee@silence-media.com.