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In order to provide the services and products which our clients require, we need to process personal information about you, our clients, our staff and our partners. As you can imagine, because we offer a lot of different services, and process significant volumes of information, trying to explain what we do in an open, easy to understand but concise way is quite difficult.
This policy is intended to explain, as honestly and clearly as we can, why we need your information, how we will use it and how we will keep it safe.
Quick Links
We are ‘We Breathe Media Limited’; in this policy we may refer to ourselves as WBM, us or we. We operate an Affiliate Network and also own a number of websites branded as the ‘Mr Company’, for example, Mr Insurer, Mr Finance and Mr Automotive, you can see a full list of our sites here.
Regardless of whether you have subscribed through an affiliate partner or a Mr Group website, we will process your information safely here centrally at WBM mostly in the UK and EU; but in some cases in countries like the USA which provide adequate protection of your information.
Our business is to help connect our clients with customers like you who may be interested in the services and products they offer. We do this by asking people to give us their permission to share their information with these brands; we also ask affiliated partners to help us identify potential customers, and these partners send emails on our behalf. You can discover more about how we do this in this [how we use your information] section.
We are a limited company registered in England under the company number 11179160 and with the Information Commissioner where our entry number is ZA451907. If we ever sell the business, or are taken over by another company, your information will be transferred to that company, but you will receive due notice of the transfer.
To connect you with our existing and new clients we need to hold and share your information, but we promise to only do this where you have given us your permission or you have agreed to our partners contacting you on behalf of our clients. At any time, you can ask us to stop contacting you, and, as long as there is no legal reason why we cannot, ask us to remove your information.
Where we are the Data Controller, in other words, where we decide and dictate how your information will be used, we promise to follow all current data protection legislation for the territory in which we are operating and the current legislation regarding electronic marketing. Where we act as what is called a data processor, this is where another company engages us to act on their behalf, we shall only process your information according to their lawful instructions.
We may collect and process your personal data for different reasons, simply click on the heading which best suits your relationship with us and find out how and why we need your information
The two main reasons we process your information is with your consent or using what is called legitimate interests. This simply means that we are allowed to process your personal details for offline direct marketing purposes as long as our activities do not override your fundamental rights and freedoms.
In order to offer our service, we work with a range of clients and partners, full details can be found here.
Helping clients identify new customers
This is referred to within the marketing industry as ‘customer acquisition’ or ‘lead generation’, we are usually helping household brands identify new customers for their products and services.
What we collect:
The information collected will depend on the exact service offered by our clients but will always entail capturing your contact details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10 PC) and other information relevant to that campaign, such as your date of birth if the product were only targeted at certain age groups e.g. 50 Year old plus for Pension Products. Any additional information will only be captured if it is relevant to the service, for example, to ensure that you are in a specific country, or to advise you of services in your locality i.e. enhance and better our service.
To ensure this information is accurate, before it is sent to the client, or added to our system we pass it to a number of third parties to verify your details, for example, phone number and address. You can see details of these processes here.
It is very rare that we will collect sensitive data, but it may be necessary for a specific campaign, for example, Private Medical Insurance for higher risk applicants, for that we needed to collect a very small amount of medical information, but we would only ever captured this with your permission.
How we collect it:
You are in charge of what information we collect. You will either be asked to enter your details on the sign-up page on our websites, or you will be emailed by one of our partners with whom you have a pre-existing relationship and will be invited to click on a link to our client’s website where you will enter your details directly with them.
Our analytics system will automatically record if you click on any of the links within an email or register as a potential customer with a client.
Why we collect it:
We have been asked by our client to help them identify new clients who may be interested in their product or service. We would also like your permission to contact you directly and you may also be invited to add your name to our mailing list. To help us monitor if the service is effective and how many new customers have been generated, we also keep a note of which hyperlinks you have clicked in both the emails and websites.
Our lawful reason for processing:
Our partners, or us, will notify you, via email, SMS, post or sometimes telephone, details of our clients based on your previous consent with our partner or us. Although where we are just processing your personal data for our own purposes and especially, for purely telephone or postal purposes, we may rely upon our legitimate interests to keep in touch.
If we, or our clients ever ask you for sensitive personal information such as medical information, then we shall ask for your ‘explicit’ consent before capturing this.
Where we store your information:
Clients will store the information you give them directly on their systems, you will need to check with them where that information is kept. If you ask to be added to our newsletter or database, we shall keep your information within the UK. Our tracking software is based in both the UK and Ireland and email broadcasting, audit and backups are held in the USA but only with organisations who are part of the Privacy Shield Scheme.
Third parties:
As we send campaigns on behalf of our clients, they are the Data Controller and will be responsible for how your data is stored and used. Where you give us permission to add your data to our mailing list, we will only further share that with other parties, clients, or send information on their behalf, if you give added consent.
To ensure you are a real person we also share your data with third parties to verify some elements of your information, we do this using some automated decision making processes. You can see details of our clients and tech partners here.
Retention:
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical data is fully or partly anonymised whilst being stored.
We will need to keep such information that enables us to comply with any requests to be forgotten indefinitely.
Other information
To try and advise you only about those products or services in which you are interested, and during the registration process to ensure that you meet certain criteria, we use several automated processes. For example, we look at which campaigns you have registered to hear about and advise you about similar products, or a particular service may only be applicable to people between a specific age range and we will calculate check you age (if you gave it to us) falls within this range. Any specific automated decisions will be advised to you in the privacy notice on that particular page, but are also listed under Tech Partners.
Your data held by We Breathe Media
The data which we hold on you will be used to both supply newsletters from us to you, and to send emails with relevant information from our clients.
What we collect:
The information we hold will depend on what you are happy to give us. However, it will always entail capturing your contact details (name, email address, address and phone number), IP address, device used (tablet, iPhone, Windows 10 PC), other information relevant to that campaign, such as [example data]. We will maintain a record of your marketing preferences, such as to which ‘Mr Company’ website you signed up, the consent wording to which you agreed and your direct marketing channel preference, for example, postal, email, SMS and so on.
You can change your mind at anytime by emailing compliance@webreathemedia.com or calling our Compliance Officer on 0207 098 9878.
To ensure the information we hold is accurate, before it is added to our system we pass it to a number of third-party companies to verify your phone number and address.
How we collect it:
The data we hold will come directly from you via our website capture form. To ensure that the information came from you, we shall send an email to the email address provided giving you full details of our service and a link to this privacy policy. We monitor and record which links within our sites and emails you click on.
Why we collect it:
We wish to maintain a list of individuals who have an interest in specific areas or topics so that we can connect our clients with new customers who may be interested in their product or service. We monitor which hyperlinks you click to help us better understand in which products you are interested.
Our lawful reason for processing:
In 9 out of 10 cases we are relying on your explicit consent to process your personal information; in these cases, you can withdraw your consent at any time, and as long as there is no legal reason why we need to retain the data we shall delete or suppress your information from our system.
In a small number of cases, and where we are emailing you about our own products or service, we can rely on our own legitimate interests and what is called a soft opt-in. In other words, if you have asked to receive details from one ‘Mr Company’ website, and we launch a similar ‘Mr’ site, we may send details of the other service to you.
If you ever make an enquiry or complaint to us, or we have ever sold a product or service to you, then we would continue to hold details on that interaction using our contractual or legal obligations.
Where we store your information:
Your data will be managed in secure servers based here in the UK. We also use a combination of email broadcast services depending on the campaign and some may be based outside of the EU, but we will only use those that can guarantee adequate protection of your information.
Third parties:
We keep you informed about developments using email broadcast companies and to ensure you are a real person we also share your data with third parties to verify some elements of your information. You can see details of our clients and partners here. We may also share your data if required to do so by law.
Retention:
We will retain your personal or analytical details for 7 years after the last point in which we interacted. Analytical data is fully or partly anonymised whilst being stored.
We will need to keep such information that enables us to comply with any requests to be forgotten indefinitely.
Other information
In order to try and advise you only about those products or services in which you are interested, and also during the registration process to ensure that you meet certain criteria, we use a number of automated processes. For example, we look at which links you have followed and advise you about similar products, or a particular service may only be applicable to people between a specific age range and we will calculate check your age (if you gave it to us) to ensure that it falls within this range. Any specific automated decisions will be advised to you in the privacy notice on that particular website.
We shall only keep the minimum amount of data on employees and prospective employees which is necessary to protect our staff and fulfil our legal obligations.
What we collect:
We will ask for your full name, contact details, date of birth, nationality, N.I number, qualifications, work experience, your photograph and photographic proof of right to work in the UK. If you are offered a position we will ask for your bank details, information regarding your marital status, health and other anti-discrimination information which you are comfortable giving us, this may include, sexuality, religion and ethnicity. Details of next of kin and other family members will be requested when necessary to support your employment.
A record of your recruitment interview, payroll, sickness, absence, performance reviews, disciplinaries and other work-related notes will be maintained. We will also keep logs of activities you perform on our ICT systems and monitor email and web usage.
How we collect it:
The data we hold will come, in the main, directly from you or via a recruitment company, we may also hold information given to us by other companies for whom you have worked or other employees or Managers. Information will usually come via application forms, normal correspondence channels through our website or through your day-to-day interactions at work.
Why we collect it:
To consider your application, offer employment, and to comply with our legal obligations, for example, to ensure your right to work within the UK, collection of ta and health and safety. Medical information and sensitive information are requested to allow us to assist you in your employment and comply with anti-discrimination laws. We ask for details of family members for emergency and legal reasons such as complying with our obligations under maternity or parental leave legislation.
Our lawful reason for processing:
The majority of information we ask for is required because the law says we must have it. Where processing of your information is not strictly necessary for your employment, for example, to use your photo in publicity campaigns, we will ask for your explicit permission to process.
We rely on our legitimate interests to keep our organisation safe, and our obligation to detect and prevent fraud or crime, and to this end we monitor computer use, emails, correspondence and web traffic.
Where we store your information:
Your data will be kept on our computer and manual files held in the UK.
Third parties:
We will share your information with those government agencies that we are required to by law, such as HMRC, the police, ICO etc. We may need to seek advice from our professional advisors and may pass your information to them under a duty of confidence. Other sharing includes with our private medical insurer, if requested confidential references for new employers and if appropriate third-party companies to verify your identity.
Retention:
For unsuccessful applicants we will retain your application form for no more than 6 months. For employees and all other workers, we will hold the information for 7 years after the last point in which we interacted. We shall delete some information earlier than this time if employment law dictates, for example, disciplinary warnings which have expired.
Other information:
Employees should read the WBM Employee Privacy Notice for full details of processing.
What we collect:
As a website visitor all we capture is your IP address, system type (PC, iPhone, Windows 10 etc) and what pages you visit. This is done via Google Analytics which is detailed below and in our Cookie Policy. At any time, you can stop the collection of your anonymous data by Google.
If you, sign up for a service with us or our clients, at that point we shall capture your name, contact and details as outlined in the ‘Your data held by We Breathe Media‘. At this point your identity will be known along with the pages you have visited.
Some of our cookies allow us to present you with adverts about our service on other sites. This is normally referred to remarketing or retargeting.
How we collect it:
Data is collected by way of cookies placed on your device – you can remove these at any time.
Why we collect it:
Some cookies are necessary to allow our sites to operate successfully. We use remarketing to remind you of our services in the hope that you will sign up for one of our sites.
Remarketing cookies are managed by third party companies, and they are listed in our partners link below here. The information which they capture is partly anonymous, in that they only have your IP address and pages visited. If at some point you sign up to one of our sites, then only then would your identity be known.
Our lawful reason for processing:
We are relying upon our legitimate interests to use cookies otherwise the sites could not run and capture anonymous or partly anonymous data to understand how the sites are working and which pages are being viewed. We ask for your consent to use tracking cookies.
Where we store your information:
We store details of your activity on our cloud server in the EU. Google Analytics and our remarketing partner are based within the EU.
Third parties:
Information from tracking cookies will be managed by third party companies, more information can be found in our cookie policy. Our website developers, IT support and marketing consultants may also access this part-anonymised data.
Retention:
Anonymised data will be kept indefinitely, other information will be deleted 3 years after the last interaction with the client. We will need to keep such information that enables us to comply with any requests to be forgotten for an indefinite period.
Sales & Marketing (to corporate prospects & clients)
What we collect:
To allow us to provide our agency services we will capture your name, company and contact details, the nature of your business and details of any colleagues with whom we may need to communicate. If you volunteer the information we may also record other details necessary to deliver the service.
We will record sensitive information, such as details of a disability or dietary requirements only if it is necessary to deliver the service to you, or you ask us.
How we collect it:
We will obtain information directly from you, either in person, via normal business channels, email, telephone, Skype and social media and, also in person, for example at networking events and conferences. We may identify your details from public domain sources and, also purchase third party data.
Why we collect it:
To help us identify new clients and manage existing relationships.
Our lawful reason for processing:
If we have identified your information via a third party or from social media, or you have made contact with us we shall rely on our legitimate interests to process your information. Where we wish to send you administrative or marketing emails, and you have contacted us, we rely on the soft-opt-in under the ePrivacy Directive to send those emails to you.
We shall only send unsolicited emails to corporate addresses and always include a valid unsubscribe option. At any time, you can ask us to stop sending these to you.
If you sign up for our newsletter this is done with your consent, and if you volunteer, or we wish to record any sensitive information about you, we will ask for your explicit consent.
If we are in negotiation with you for goods or services then we will either have in a place a contract or be in negotiations to enter into one, and in these cases, we rely on contractual obligations to process your information.
If we need to seek legal advice or recover an outstanding debt we shall rely on our legitimate interests to pursue a legal claim.
Where we store your information:
Your information will be hosted in the UK, campaign data in the EU and email broadcasts will be in the USA under the Privacy Shield Scheme.
Third parties:
We will not share your personal information with any third parties save with your permission, as required by law, or as explained above, to protect our legitimate interests.
Suppliers, partners and affiliates with whom we have working contractual arrangements
What we collect:
We will capture your name, company and contact details, the nature of your business and details of any colleagues with whom we may need to communicate. If you volunteer the information we may also record other details necessary to deliver the service.
We will record sensitive information, such as a disability or your dietary requirements if it is necessary in order to deliver the service to you, or you ask us.
In addition, at an organisational level, we will maintain details of contracts, financial transactions, campaigns, click counts and so on, but no additional personal data will be captured.
How we collect it:
We will obtain information directly from you, either in person, via normal business channels, email, telephone, Skype and social media etc and, also in person, for example at networking events and conferences.
Why we collect it:
To enable us to manage the commercial relationship and meet our contractual and legal obligations.
Our lawful reason for processing:
For a commercial relationship to be in place contracts will be required and this is the main lawful basis for processing. If any information is required or requested which is not required as part of the contract we shall, in the first place rely upon our legitimate interests for those elements which are necessary for the relationship, and your consent for those elements which are only desirable.
If we need to seek legal advice or recover an outstanding debt we shall rely on our legitimate interests to pursue a legal claim.
Where we store your information:
Your information will be hosted in the UK and EU, email broadcasts will be in both the EU and the USA under the Privacy Shield Scheme.
Third parties:
We will not share your personal information with any third parties save with your permission, as required by law, or as explained above, to protect our legitimate interests for example by seeking legal or professional advice and the recovery of any debts.
We only target, and knowingly process details of individuals of 18 years of age and older. Unless data is entered accidently or maliciously by a user, client or other third party, we will never deliberately process data of children.
At all times we, and the processors for which we are responsible will process your information in line with current UK data protection and electronic marketing legislation. We will put in place sufficient organisational and technical measures to keep your information safe, and where possible store your information in the UK or EU.
All of our staff are trained in data protection and we also have in place confidentiality agreements to further protect your information. We try, as far as is possible, to ensure that all partners have similar protections in place.
Occasionally we may use a service, such as an email broadcast platform, which is hosted outside of the EU, but we will take all due care to ensure the safety and security of your information. We shall only use companies outside of the EEA if the EU has deemed them to have adequate data protection measures, or in the case of the USA are part of the Privacy Shield Scheme.
We use a number of automated processes to validate details given to us, check certain criteria, for example age or eligibility, and to understand which products are of interest to you.
These automated decisions do not affect your fundamental rights, nor affect you in a legal way but are listed under Tech Partners here.
See your rights below for objecting to any processes.
The Data Protection Act and GDPR affords Data Subjects (that is people whose information we capture) certain rights and these are listed below for your convenience: -
The broad principle underpinning this right is to enable an individual to request the deletion or removal of personal data where there is no compelling reason for its continued processing by us or our partners.
For some processing you will have given us permission to process your information, and in these cases, you can withdraw your consent at any time. In certain situations, these rights may not apply, for example if you entered into a membership minimum term contract, we may have to write to you about your membership even if you asked us previously not to, but we would not send you direct marketing.
To activate any of your rights contact us on the details below.
Last Updated 01/01/2020
Cookies are small files of letters and numbers stored on your browser or device that enable the cookie owner to recognize the device when it visits websites or uses online services. The website you visit may set cookies directly, known as first-party cookies, or may trigger cookies set by other domain names, known as third-party cookies. While we may automatically use some cookies that are strictly necessary to provide the services you request or enable communications, we request your consent for all of our other cookie uses.
Types of Cookies We Use
Our Privacy Policy (https://www.webreathemedia.com/privacy-policy) describes our practices for any personal data that our first-party cookies collect, store, or use, including our legal basis for processing personal data. We rely on our legitimate interest to process essential and functional cookies, and your consent for other cookies.
Except for strictly necessary cookies, all first-party cookies set by this site will not expire after your last website visit. Third-party cookie expiration periods are set by their respective owners.
Please see our cookie table for a list of the individual first-party and third-party cookies potentially used on this site and their specific purposes.
Cross-Border Data Transfers
The cookies we use may process, store, or transfer personal data in and to a country outside your own, with privacy laws that provide different, possibly lower, protections. You consent to this transfer, storing, or processing when you consent to our cookie use. We are based in the United Kingdom, please review the third-party cookie provider’s policy to learn more about its location.
Your Cookie Choices
Please visit our consent manager tool [URL] to make or manage your cookie use preferences.
Most web browsers allow you to directly block all cookies, or just third-party cookies, through your browser settings. Using your browser settings to block all cookies, including strictly necessary ones, may interfere with proper site operation.
Changes to Our Cookie Uses
We will post any changes to the way we use cookies on this page and indicate on our website(s) that we updated this cookie notice. If the changes materially alter how we use cookies, we will post a notice on our website and request your consent for the materially different use.
Please check back frequently to see any updates or changes to our cookie use notice.
Contact Information
Please compliance@webreathemedia.com any questions, comments, or requests regarding this cookie use notice
The Compliance Officer
WE BREATHE MEDIA LIMITED
Capital Tower
91 Waterloo Road
London, SE1 8RT
Full details can be found in our Privacy Policy (https://www.webreathemedia.com/privacy-policy)
Cookies Used on We Breathe media and Mr Brand Websites
The following table lists all cookies potentially in use on the We Breathe Media and Mr Brand websites. We will update this table as our website changes and evolves, so please check back frequently to review any new cookie uses. Visit our We Breathe Media Cookie Policy for more information and choices about our cookie use, including our contact information and complaint procedures.
Last Updated 01/01/2020
| Cookie Category | Cookie Name and Owner | Purpose | More information |
|
[Necessary] [Analytical or Performance] [Functional] [Advertising or Tracking] [Third-Party] [OTHER COOKIE CATEGORY] |
[COOKIE NAME] [COOKIE OWNER] |
[DESCRIPTION OF THE PURPOSE FOR WHICH THE COOKIE IS USED] [This cookie [is essential for our site to/enables us to]:
|
[Session Cookie/Persistent Cookie that expires [DURATION]]. [SAMPLE OF INFORMATION STORED OR TRANSMITTED BY THE COOKIE] [LINK TO EXTERNAL INFORMATION] |
Changes to This Privacy Notice
Businesses develop over time, and we reserve the right to update this Privacy Notice at any time, and we will provide you with notice of any significant changes. If we would like to use your previously collected personal data for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal data for a new or unrelated purpose.
We may process your personal data without your knowledge or consent where required to do so by law, or instructed by a UK, or in certain circumstances, EU court.
If you have any questions or concerns do not hesitate to contact us.
The Compliance Officer
WE BREATHE MEDIA LIMITED
91 Waterloo Road
London, SE1 8RT
T. 0207 098 9878
E. compliance@webreathemedia.com
ICO Registration Number: ZA451907
Companies House Registration number: 11179160 (registered in England)
We hope that the service and experience provided by We Breathe Media Ltd is a good one, however, we do realise that matters don’t always go as planned, and therefore this policy explains how We Breathe Media will deal with any concerns you may have about the service received.
How do I make a complaint?
If you do have a concern or complaint, please contact us as soon as you are aware of the problem, in order for this to be addressed. You can contact us by:
Telephone: 0207 098 9878
Email: info@webreathemedia.com
Post:
Complaints
Capital Tower
12th Floor
91 Waterloo Road
London
SE1 8RT
Please include the following information:
What happens next?
We will send you a letter acknowledging receipt of your complaint within five days of our receiving the complaint, enclosing a full copy of the complaints procedure and advising you who will be responding to the complaint. We aim to resolve your complaint fully within 21 days of sending you the acknowledgement letter.
What happens if I am unhappy with the response?
The matter will be referred to our Managing Director, Piers de Grouchy, who will consider the complaint further.
Information Commissioners Office
If you are unhappy with how we have processed your information, you have the right to lodge a complaint with the Office of the Information Commissioner, contact details below.
Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire, SK9 5AF
Helpline: 0303 123 1113 (local rate) or +44 1625 545 745
Capital Tower
91 Waterloo Road
London SE1 8RT
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