We take your privacy seriously and will only use your personal information to respond to your request and as required to run our business. We will never sell, share or use your personal information other than as described here and/or as explained when we collect your data.
Who We Are And How To Contact Us
Post: 5-9 Main Street Gibraltar GX11 1AA
Client Flo Media Limited is the Data Controller, we are legally responsible for how that information is stored and processed. In some situations, we are Joint Data Controller with our partner. We will ensure that we have appropriate Data Sharing Agreements in place to clearly define roles and responsibilities when processing your data.
Frequently Asked Questions
How will my data be used?
Client Flo Media Limited will collect your data securely on our website and may contact you to confirm by phone, SMS, Email or the chat on our website to confirm some details or product requirements. We may also contact you to ask about your experience using our site or service.
What data will be stored?
We will store your personal details in order to provide to respond to your request. The data stored would typically include your name and/or business name, address, email address, phone number and details about the product or service your are looking for.
What data will be shared?
We will only share your data with our partners to provide a quote for the product or service that you requested information about and as explained when we collect your data. We may need to share your information with any regulator or legal body that requests it.
How long will you store my data?
Your data will be stored as explained in our Data Retention Document. Where we collect your data as part of a marketing campaign run by us or on behalf of our partner, we will store your data for no longer than 6 months after last contact.
If you wish to see a copy of our Data Retention Document, please contact us.
Who can access my data?
Access to your data is carefully controlled and access will be limited to only authorised personnel.
How is my data kept secure?
We will store your data on secure EU based servers. We use industry approved security protocols/technology to secure data at all times. Our Information Security policy explains this in more detail, if you wish to see a copy, please contact us.
Client Flo Media Ltd is a marketing company. Processing of your data is required in order to run our company and our marketing services.
This policy applies to individuals who have shared their data with Client Flo Media Ltd in any capacity, and to individuals whose data we have collected as part of providing our own Marketing operation.
It applies to all data that the company holds relating to identifiable individuals, even if that information technically falls outside of the GDPR. This can include:
- Names of Individuals
- Postal addresses
- Email Addresses
- Telephone numbers
- Personal information
- Financial information
- Technical information about devices, sites, ip address, and use of the internet
- Other information as required to provide our services and operate our company
How will we use your data?
This section describes the lawful basis for processing data and applies to information about individuals that we collect, store, or process for all sources. This includes:
- The Information you provide when you contact us
- When you contact us in order to discuss the products and services we offer
- Information we collect about how you use the website, apps, the internet, or other online properties
- Information that is given and stored as part of any ongoing relationship
- Information we collect as part of our marketing operation
We do not routinely collect or process sensitive data, where this occurs we will take appropriate precautions with this data.
We will only use your personal data for the purposes for which we collected it and as you would reasonably expect your data to be processed and only where there is a lawful basis for such processing. Here are some examples of how your data is processed.
When you provide your details to us
Types of data collected: Identity, Contact, Personal Information
Lawful basis of processing: Performance of a contract with you, with your consent, and/or in our legitimate interest of the interests of a third-party
To process and deliver the services you request including managing payments, fees, and charges, and to collect and recover money owed to us
Types of data collected: Identity, Contact, Financial, Transaction, Marketing & Communications
Lawful basis of processing: Performance of a contract with you and Necessary for our legitimate interests to recover debts owed to us
Types of data collected: Identity, Contact, Profile, Marketing & Communications
Lawful basis of processing: Performance of a contract with you, Necessary to comply with a legal obligation and Necessary for our legitimate interests to keep our records updated and to study how customers use our services, with your consent
To administer, protect our business and our site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
Types of data collected: Identity, Contact, Technical
Lawful basis of processing: 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, Necessary to comply with a legal obligation, with your consent
To deliver relevant content and advertisements to you and measure and understand the effectiveness of our advertising
Types of data collected: Identity, Contact, Profile, Usage, Marketing & Communication, Technical
Lawful basis of processing: Necessary for our legitimate interests to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy
To use data analytics to improve our website, services, marketing, customer relationships and experiences
Types of data collected: Technical, Usage
Lawful basis of processing: Necessary for our legitimate interests to define types of customers for our services, to keep our site updated and relevant, to develop our business and to inform our marketing strategy
To make suggestions and recommendations to you about products and services that may be of interest to you
Types of data collected: Identity, Contact, Technical, Usage, Profile
Lawful basis of processing: Necessary for our legitimate interests to develop our services and grow our business
To operate our Marketing company and provide our services to our Business Partners
Types of data collected: Identity, Contact, Financial, Life style, Professional, Technical, Other information as required
Lawful basis of processing: Necessary for our legitimate interests and the legitimate interests of our clients to develop services and grow our businesses
To create custom and lookalike/similar audiences
Lawful basis of processing:
In accordance with your preferences, we may also use your personal information to provide you with information about services and promotions that may be of interest to you. This includes any of the following:
- Information that you provide when completing an online form, application, or send your details to us
- Information relating to any use you make of our services, including any other transaction details (including your address, telephone number and financial details)
- Technical information we collect about you including cookies and information about your visit to our sites, apps, and other properties.
- Information we collect about you from other sources such as directories, social media, third-party databases, and other companies
- Data we receive will be used for the purposes it was provided, including:
- To respond to queries about our services
- To provide you with information about related products and services we believe you will be interested in
- For our Business Partners to send you offers, promotions, information or other content we think you will be interested in
- To operate and grow our business
- In relation to our Business Partners, data we receive could also be used by us to run our business, including:
- To carry out our obligations arising from any contracts entered into between our Business Partners and us including the provision of services, and to respond to queries regarding those contracts
- To manage and administer the relationships between our Business Partners and us
- Develop and maintain our websites, apps, and other services
- To obtain feedback about our services
You will be able to change your preferences at any time as described in the section below – how to opt out.
How to opt out
You can opt out of receiving contact from us at any time. You also have the right to request that any of your personal data is deleted at any time. Please contact us with your request.
What are your rights?
If we have collected, stored, or processed your data as part of running our business we will at all times respect your rights as an individual and ensure we meet our obligations professionally and courteously. We operate in line with EU GDPR (May 2018) data protection guidelines.
We respect your rights and will respond to any request for access to personal information and requests to delete, rectify, transfer, data and to stop processing.
We will also advise you on how to complain to the relevant authorities, namely the Information Commissioner’s Office. Any requests or objections should be made in writing to the Data Controller or you can visit our website, call, or email us to contact us to change your preferences at any time.
Under certain circumstances, you have rights under the data protection laws in relation to your personal data. These include the right to:
- Request access to your personal data
- Request correction of your personal data
- Request erasure of your personal data
- Object to processing of your personal data
- Request restriction of processing your personal data
- Request transfer of your personal data
- Right to withdraw consent
You can see more about these rights at: https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/
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.
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
How is your data stored and processed?
Your data will be collected, stored and processed in the EU only. We do not transfer your data outside the EU. Your data will generally not be stored for more than 6 months after the end of our relationship to ensure we have records of service, payments, and other interactions we have with you.
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 find out more about how the processing for the new purpose is compatible with the original purpose, please email us. If we need to use your personal data for a purpose unrelated to the purpose for which we collected the data, we will notify you and we will explain the legal ground of processing.
We may be legally obliged to disclose your personal information without your knowledge to the extent that we are required to do so by law; in connection with any ongoing or prospective legal proceedings; in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk); to any person who we reasonably believe may apply to a court or other competent authority for disclosure of that personal information where, in our reasonable opinion, such court or authority would be reasonably likely to order disclosure of that personal information.
Who do we share your data with?
We may share your personal data with the parties set out below for the purposes described in this document:
- Service providers who provide IT and system administration services
- Hotjar – To record information about visitors to our website and their journey
- Professional advisers including lawyers and insurers who provide consultancy
- Third parties to whom we sell, transfer, or merge parts of our business or our assets
- Third parties as required to run our business and provide our services to our Business Partners
- Our Business Partners, and other third-parties, who we identify when we collect your details or when you submit your information and give us consent to share your details with these companies
- Other software and service providers we use to provide our services
We are a marketing company and as such we will share your details with our Business Partners who will contact you to promote their products and services. We will ensure that our Business Partners understand their obligations under GDPR and have taken reasonable precautions to keep your data safe. We will only share your data with your consent or as you would reasonably expect. You can remove your consent at any time.
We require our Business Partners to whom we transfer your data to respect the security of your personal data and to treat it in accordance with the law. We only allow such Business Partners to process your personal data for specified purposes and in accordance with our instructions.
Internet Advertising and Social Media Channels
We use social media and internet advertising channels to collect data. Our lawful basis for this is consent and/or our legitimate interest and the legitimate interest of our Business Partners pursuant to Article 6 para. 1 lit. f of the GDPR.
We use a range of channels including:
Google [advertising and display network]
Analysis and advertising tools
We conduct analysis of user behaviour and website visits in order to improve our website and marketing. This is done on the basis of Art.6 1lit. f of the GDPR.
This website uses Google Analytics, a web analysis service. These are operated by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. (“Google”). In this context, Google servers are accessed in the USA. Google also complies with certain legal frameworks relating to the transfer of data, such as the European Union (EU)-US and Swiss-US Privacy Shield Frameworks. In order to effectively implement the strict European data protection requirements.
When IP addresses are processed by Google Analytics, they are made anonymous. This means that these are usually reduced before a transmission outside the EU or the European Economic Area (EEA) and in exceptional cases immediately after the transmission there. This anonymised data is used for the purpose of analysing the use of this website and providing other services in connection with this website. The collected data will not be merged with other data held by Google.
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 as a business need to know such data. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality.
We will report any breaches or potential breaches to the appropriate authorities within 24 hours and to anyone affected by a breach within 72 hours. If you have any queries or concerns about your data usage, please contact us.
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.
A cookie is a small file which asks permission to be placed on your computer’s hard drive. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences. We use traffic log cookies to identify which pages are being used. This helps us analyse data about webpage traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
Strictly Necessary Cookies
These cookies are necessary for the website to function and cannot be switched off in our systems. They are set in response to actions made by the user in the website and are required to identify irregular site behaviour, prevent fraudulent activity, and improve security.
You can set your browser to block or alert about these cookies, but some parts of the site will then not work. These cookies do not store any personally identifiable information.
Performance cookies and analytics technologies
These cookies collect information about how visitors and users use our websites and services, for instance which functionality visitors use most often, and if they get error messages from areas of the websites or services. These cookies do not collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our websites and services work.
These cookies allow our websites and services to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features.
These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customise. They may also be used to provide services you have asked for. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.
Targeting or advertising cookies
These cookies are used to deliver adverts more relevant to you and your interests. They are also used to limit the number of times you see an advertisement, as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often, targeting or advertising cookies will be linked to site functionality provided by the other organisation.
For further details in how these networks process personal data, please find a link to their respective privacy policies.
Facebook Advertising: https://www.facebook.com/privacy/explanation or visit https://www.facebook.com/help/610457675797481/?helpref=hc_fnav to see how your data is used on Facebook Ads
Bing Ads: https://privacy.microsoft.com/da-dk/privacystatement
Taboola Ads: https://help.taboola.com/hc/en-us/articles/360004904154-Taboola-s-Trust-Center
Outbrain Ads: https://www.outbrain.com/help/advertisers/outbrain-gdpr/
Google Ads: https://policies.google.com/privacy?hl=en&gl=ZZ
We have completed a Legitimate Interest Balancing Assessment and as such we have determined that our processing is reasonable and the rights of any individual are not adversely affected. We take these rights seriously and will review this assessment regularly.
Contacting us, exercising your information rights and Complaints
We fully comply with Data Protection legislation and will assist in any investigation or request made by the appropriate authorities.
If you remain dissatisfied then you have the right to apply directly to the Information Commissioner for a decision.
The Information Commissioner can be contacted at:
Information Commissioner’s Office