Version 6 – October 2021

Important notice

This privacy notice sets out how we collect and process your personal data. This privacy notice also provides certain information that is legally required and lists your rights in relation to your personal data.

This privacy notice relates to personal information that identifies you as a natural person (whether you are an actual or potential customer, an individual who browses our website or an individual outside our organisation with whom we interact). We refer to this information throughout this privacy notice as personal data or personal information and further detail of what this includes are set out in this privacy notice below.

The privacy and security of your personal information is very important to us so we want to assure you that your information will be properly managed and protected by us at all times.  Please read this privacy notice carefully as it explains how we may collect and use your personal data.

This privacy notice may vary from time to time so please check it regularly.  This privacy notice was last updated on 1st October 2021.

How to contact us

Controller and contact details

For the purposes of relevant data protection legislation, we are a controller of your personal data.  As a controller we use (or process) the personal data we hold about you in accordance with this privacy notice.

If you need to contact us in connection with the use or processing of your personal data, then you can do so using our contact details as set out below.

Data Protection Representative

Our Data Protection Representative is Carla Preston whom you can contact at c.preston@robertgerrard.com

What information we hold about you and where we obtain this from

  • The personal data that we collect about you may include the following information:
  • Personal data you provide to us in person, via our website or by telephone
  • Personal data you provide when you enquire about insurance, or when you purchase a policy, through us, including information about what and/or who you want to insure, such as vehicle details, business activities, your home or travel details
  • General information about you, such as your name, address, contact details and date of birth
  • Personal data you provide if you subscribe to any of our mailing or newsletter services
  • Your claims and credit history
  • Financial details, such as your bank account and card details
  • Criminal convictions
  • Information about your use of our website such as your IP address, which is a unique number identifying your computer, including personal data gathered using cookies

In addition, we may obtain certain special categories of your data (special categories of data) and data about criminal convictions, and this privacy notice specifically sets out how we may process these types of personal data. The special categories of data are data concerning health.

We collect your personal data from you as a controller when we obtain quotations for insurance for you, when we set up your policy for you and when we make changes to your policy for you. This may also involve the collection of data from or about others who are associated with you and your insurance policy such as other persons insured on your policies or your employees or representatives. By giving us information about someone else for the purpose of arranging insurance for them under your policy such as named driver, employee or travel companion etc. you confirm that you have their permission to do so and that you have shared this privacy notice with them.

By asking us to arrange a contract of insurance for you where this involves passing information to us relating to children, you confirm to us that in doing so you are the responsible guardian of the child.

We also collect information from publicly available sources and third-party databases made available to the insurance industry for the purposes of reducing fraud and financial crime as well as any other third-party databases where your personal data may be held, provided such third parties have lawful bases on which to share such personal data with us.

How we use your personal data and the lawful basis for doing so

Where we are relying on a basis other than consent

We may rely on one or more of the following legal bases when processing your personal data for the following purposes:

Purposes for which we process your personal data The basis on which we can do this (this is what the law allows)
In order to perform our contractual obligations to you. This would include our fulfilling your requests for insurance services (including obtaining insurance for you, fulfilling requests for mid-term adjustments and obtaining renewals) The processing is necessary in connection with any contract that you may enter into with us
To administer your account, including financial transactions for insurance broking The processing is necessary in connection with any contract that you may enter into with us
To assist in the prevention and reduction of fraud and other financial crime The processing is necessary for us to comply with the law and our legal requirements
In the interests of security and to improve our service, telephone calls you make to us may be monitored and/or recorded The processing is necessary to pursue our legitimate interest in the management and operation of our business
To let you know about similar products and services that may be of interest to you The processing is necessary to pursue our legitimate interest in operating our business
To make automated decisions, automated profiling and fraud detection The processing is necessary in connection with some contracts that you may enter into with us

Special categories of data and criminal convictions

We may also need to collect special categories of data from you such as information about your health, personal data revealing racial or ethnic origin, religious or philosophical beliefs or trade union membership and generic data.  We may also collect information on criminal convictions which we may share with third parties.  The lawful basis on which we can do this is the processing is necessary for reasons of substantial public interest relating to insurance purposes.

Insurance purposes mean (a) advising on, arranging, underwriting or administering an insurance contract (b) administering a claim under an insurance contract or (c) exercising a right or complying with an obligation, arising in connection with an insurance contract, including a right or obligation arising under an enactment or a rule of law.

Who we pass your personal data to

We may need to pass your personal data to other companies which may include:

  • Other companies or brands within our group of companies, for example if we are unable to provide a suitable insurance policy on request or at renewal we will check if any of our associated group companies can provide you with suitable cover
  • The insurers, intermediaries and third party service providers that we use for the purpose of arranging and administering your insurance policy. This may also include risk management assessors, uninsured loss recovery agencies, premium finance providers and other third parties involved (directly or indirectly) in the administration of your insurance and its associated benefits
  • Firms that provide administration and processing services to us or on our behalf under contract in order to complete activities such as claims handling, IT systems and administrative services and other activities set out in this privacy notice, as well as support activities such as finance and auditing services
  • Organisations that have a specific role laid out in law, such as statutory bodies, regulatory authorities and other authorised bodies
  • Other organisations where we have a duty to or are permitted to disclose your personal information by law, for example if we received a valid request from the police or other third party organisation in the interest of preventing and detecting crime
  • Fraud prevention agencies and operators of registers available to the insurance industry to check information and prevent fraud
  • Credit reference agencies to check your credit history. This check will be recorded on your credit reference file without affecting your ability to apply for credit or other financial products
  • Third parties we use to recover money you may owe us or to whom we may sell your debt
  • Another company, if our business or part of it is bought or taken over by that company to make sure your insurance policy can continue to be serviced or as part of preliminary discussions with that company about a possible sale or take over

The information you share with us may be transferred by us or any of the types of firms or organisations we have noted above, to other countries in order for processing to take place, including locations outside of the UK.  We will only do so if there are adequate levels of protection in place as required by applicable data protection laws.

Accessing our website and cookies

When you visit one of our websites, we may collect information from you, such as your email address, IP address and other online identifiers. This helps us to track unique visits and monitor patterns of customer website traffic, such as who visits and why they visit. We use third parties to collate IP addresses to help us understand our Internet traffic data and data regarding your browser type and computer. We may also use web usage information to create statistical data regarding the use of our website.  We may then use or disclose that statistical data to others for marketing and strategic development purposes, but no individuals will be identified in such statistical data.

We may use cookies and/or pixel tags on some pages of our website.  A cookie is a small text file sent to your computer. A pixel tag is an invisible tag placed on certain pages of our website, but not on your computer. Pixel tags usually work together with cookies to help us to give you a more tailored service. We also use cookies and pixel tags in our email communication to personalise the email and track whether the email has been opened and whether the recipient has used any website links contained in the email communication. This allows us to monitor and improve our email communications and website. Useful information about cookies, including how to remove them, can be found at https://allaboutcookies.org .

Internet browsers normally accept cookies by default, although it’s possible to set a browser to reject cookies. However, refusing to accept cookies may restrict your use of our website and/or delay or affect the way in which our website operates. You can find more information on cookies when you visit our website.

The open nature of the internet is such that data may flow over networks without security measures and may be accessed and used by people other than those for whom the data is intended. While this is outside of our control, we do take the protection of your information very seriously and aim to apply appropriate levels of security at all times.

Closed circuit television (CCTV)

Where CCTV is used, we have identified and documented the potential impact on individuals’ privacy and have taken this into account when installing and operating the CCTV system. We regularly review whether CCTV is still the best security solution.

We will clearly inform individuals of our use of CCTV and we only retain recorded CCTV images for long enough to allow for any incident to come to light (e.g. for a theft to be noticed) and to investigate it.  We will respond to individuals or organisations making requests for copies of their images on our CCTV footage and will seek prompt advice from the Information Commissioner where there is any uncertainty. We securely store CCTV images, limit access to authorised individuals and regularly check that the CCTV system is working correctly.  We have a nominated individual who is responsible for the operation of the CCTV system.

Telephone Recording

All telephone conversations are recorded, and any objections should be raised immediately. Telephone recordings will be stored securely for no longer than necessary and you have the right to request a copy where this is still available.  The call recordings will only be passed to third parties where we have a legal right or legal obligation to do so.  Payment card data is protected in accordance with the Payment Card Industry Data Security Standard (PCI DSS) and our system prevents us from recording Sensitive Authentication Data (SAD) or where this is not possible, is immediately deleted after card authorisation.

Your rights

We will only store your data for as long as is necessary to comply with the requirements of your insurance contract(s) and any legal obligations or lawful processing conditions that may exist as a result.  You have a number of rights concerning the personal information we use, which you may ask us to observe. In some cases, even when you make a request concerning your personal information, we may not be required, or be able to carry out your request as this may result in us not being able to fulfil our legal and regulatory obligations under the lawful processing conditions under which we hold your data or because there is a minimum statutory period of time for which we have to keep your information. If this is the case, we’ll let you know our reasons.

You can ask us to:

  • Provide a copy of your personal information
  • Correct or delete unnecessary or inaccurate personal information
  • Restrict or to object to the use of your personal information at any time
  • Object to any automated decision, including profiling which may have been used by insurers when underwriting your quotation. Where an automated decision has been made, we will advise you of this and of your rights
  • Provide your personal data in a structured, commonly used and machine-readable format and to have your personal data transferred to another controller. This right only applies where our processing of your personal data is automated and the processing took place initially with your consent or for the performance of a contract with you

Where we rely on your consent to use your personal information, you can withdraw that consent at any time.  Where your consent is withdrawn, your previous consent will remain valid in respect of our use of your information prior to the date you withdrew it, or if any marketing material has been sent prior to you advising that you don’t want us to contact you again

If you have any questions or concerns about this privacy notice or your data protection rights, please contact us using our details set out at the beginning of this privacy notice.

You also have the right to make an enquiry or to complain to the Information Commissioner’s Office (ICO) if you are unhappy with our use of your data, or if you think we have breached a legal requirement.  Further details about the ICO are available at:  www.ico.org.uk .

How we contact you about other products and services 

We may from time to time process your personal data to let you know about similar products and services that may be of interest to you. This is because we value your custom and we pride ourselves in offering professional and tailored advice which meets your specific insurance needs.  This includes keeping you informed on the latest insurance and industry information and details of any offers or promotions relating to the insurance services we provide to you.  Our lawful basis for processing your personal data in this way is as is necessary to pursue the legitimate interests of our business, unless we have otherwise obtained your consent to do so.  We may contact you by post, telephone or e-mail. You will be given the option to stop receiving any communications from us in this regard at any time however please note that this will not affect us contacting you about the servicing of products that you have specifically requested from us.

PRIVACY POLICY

Media Comms Ltd. (“we”, “us” or “our”) is committed to protecting and respecting your privacy.

This policy sets out the basis on which any personal data we collect from you or that you provide to us will be processed by us.

It is important that you read this privacy policy together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements the other policies and notices and is not intended to override them.

For the purposes of the Data Protection Act 2018, the General Data Protection Regulation ((EU) 2016/679) (“GDPR”) and all successor legislation to the Data Protection Act 2018 and the GDPR (the “Data Protection Legislation”), the data controller is ES Broadcast Hire Ltd., a company registered in England and Wales with company no. 07976891 and whose registered office is at 4th Floor, The Anchorage, 34 Bridge Street, Reading, RG1 2LU.

1. Information we collect from you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (known as “anonymous data”).

We may collect, use, store and transfer the following data about you:

  • Information you give us. This is information about you that you give us by filling in forms on our website or by corresponding with us by phone, e-mail or otherwise. It includes information you provide when you set up an online account, order our goods or services, make an enquiry, subscribe to our services or publications, request marketing to be sent to you, when you report a problem with our site and when you give us feedback. The information you give us may include your title, name, address, e-mail address, phone number, Skype address, job title and company, username and password, financial and payment information, copies of your passport or other official identification documentation.
  • Information we collect about you. With regard to each of your visits to our site we may automatically collect the following information:
    • technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform;
    • information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for, abandoned shopping cart information, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number.
  • Information we receive from other sources. We may receive personal data about you from various third parties including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers.

We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. However, if we combine or connect aggregated data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any special categories of personal data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

2. Uses made of your information

We will only use your personal data when the law allows us to. Most commonly, we will use your personal information:

  • to carry out our obligations arising from any contracts entered into between you and us or to take steps at your request before entering into any contracts;
  • to comply with any legal obligations to which we are subject;
  • where it is necessary for our or a third party’s legitimate interests, including for the purposes of preventing fraud, except where such interests are overridden by your interests or fundamental rights and freedoms; or
  • where you have provided your express opt-in consent.

3. Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.

Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest
To register you as a new customer and/or to set up an online account Identity, contact details (a)    Performance of a contract with you or steps taken at your request before entering into any contract with you

(b)    Necessary to comply with a legal obligation
To process and deliver your order including:

(a) Manage payments, fees and charges;

(b) Collect and recover money owed to us;

(c)   Provide goods and/or services to you.

 Identity, contact details,   passport details (a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

(c) Necessary to comply with a legal obligation
To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy;

(b) Asking you to leave a review or take a survey

 Identity, contact details, and marketing preferences (a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)
To administer and protect our business and our website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) Identity, contact details and technical data such as IP address (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you Identity, contact details, technical data such as IP address, marketing preferences Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)
To use data analytics to improve our website, products/services, marketing, customer relationships and experiences Technical data such as IP address Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)
To make suggestions and recommendations to you about goods or services that may be of interest to you Identity, contact details, usage data and marketing preferences Necessary for our legitimate interests (to develop our products/services and grow our business)
To send you updates about our services and products Identity and contact details Consent

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We may use your identity, contact details, usage data, technical data and marketing preferences to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

You will receive marketing communications from us if you have requested information from us or purchased products or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

We will get your express opt-in consent before we share your personal data with any other company for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.

Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

4. Disclosure of your information

We may have to share your personal information with the third parties set out below, or any other third parties notified to you, for the purposes set out in paragraph 3 above:

  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK.
  • Regulators and other authorities who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.
  • Fraud prevention agencies.
  • Any of our group companies.
  • Service providers and sub-contractors including delivery partners, warranty providers and website designers.
  • Finance providers.
  • Credit reference agencies.
  • Google Analytics, our analytics provider.
  • Mailchimp, our marketing email platform.
  • Paperless Post, .

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

5. International transfers

Many of our third parties are based outside the European Economic Area (“EEA”) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • Wherever possible, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
  • Where we use certain service providers in countries that have not been deemed  to provide an adequate level of protection for personal data by the European Commission, we will only transfer data where we are able to use specific Standard Contractual Clauses approved by the European Commission which give personal data the same protection it has in Europe.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. Data security

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.

However, the transmission of information via the internet and by email is never completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site or provided to us by email; any transmission is at your own risk.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

7. Retention

We will only retain your personal information for as long as is necessary to carry out the purpose for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.

To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

8. Your rights

Under the Data Protection Legislation you may be entitled to the following rights:

  • Where you have provided your consent to the processing of your personal data for any purpose, you have the right to withdraw such consent at any time by contacting us at 14 Arlington Square, South Woodham Ferrers, CM37BF or by email to help@media-comms.co.uk.
  • You can ask us to rectify any inaccuracies in the personal information that we hold about you.
  • To request the erasure of personal information that we hold about you where there is no good reason for us to continue processing it, where you have successfully exercised your right to object to processing, where we may have processed you information unlawfully or where we are required to erase your personal data to comply with local law.
  • To object to our processing of your personal data where we are relying on a legitimate interest (or that of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  • To restrict our processing of your personal data (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  • To request a copy of your personal data from us in a commonly used and machine-readable format or that we transmit your personal data to another data controller.
  • Not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you.
  • To access information held about you. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

You can exercise any of the above rights at any time by contacting us at 14 Arlington Square, South Woodham Ferrers, CM37BF or by email to help@media-comms.co.uk.

9. Links to and from our site

Our site may, from time to time, contain links to and from the websites of our partners and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any personal data to these websites.

10. Changes to your personal data

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

11. Changes to our privacy policy

Any changes we make to our privacy policy in the future will be posted on this page. Please check back frequently to see any updates or changes to our privacy policy.

12. Cookies

Our website uses cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site. Our cookie policy is available at https://media-comms.co.uk/cookie-policy.

13. Contact

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to 14 Arlington Square, South Woodham Ferrers, CM37BF or by email to help@media-comms.co.uk.

If you have any complaints relating to our privacy policy or our use of your personal data, please contact us at 14 Arlington Square, South Woodham Ferrers, CM37BF or by email to help@media-comms.co.uk. You also have the right to make a complaint to your local regulator in relation to data protection issues. In the UK, the Information Commissioner’s Office (ICO) is the relevant authority and further information can be found at www.ico.org.uk.