(Last updated: May 2018)
Flixmedia Limited (“Company”, “we,” “our,” or “us”), a company registered in England and registered address Unit 1 the Technology Park, Colindeep Lane, London NW9 6BX, believes in protecting the personal data it collects from individuals (“users”) that access or use this website (the “website”) and takes seriously its obligation to comply with its obligations under applicable data privacy laws including, without limitation, the General Data Protection Regulation (“GDPR”). The Company is a data controller as defined in the GDPR.
We are a data controller of users’ personal data (detailed below) which is collected through electronic communications or through website usage, such as when users visit the website, submit queries through the Flixmedia “contact us” feature, or as otherwise described in this notice.
Personal data we collect
For purposes of this policy, “personal data” means any information relating to an identified or identifiable natural person. We process the following types of personal data:
- Name (if provided)
- Email Address (if provided)
- Telephone Number (if provided)
- Company / Organisation that you are contacting Flixmedia from (if provided)
- IP Address if interacting with Flixmedia services on a retailer’s website
We collect your personal data using both “active” and “passive” means.
- Active means. The Flixmedia website actively collects personal data from users by asking specific questions and permitting users to communicate directly with us, for example via e-mail or feedback forms. Some areas of the website may also require a user to submit information, including personal data, to register for certain services or benefits, such as syndication services.
We process your personal data on several different legal bases, as follows:
- Our legitimate interest – if you are visiting our website or contacting us electronically, you are most likely an employee or representative of a partner, client or customer of our international content provision business. If you are visiting a retailer website, you are most likely a customer or potential customer of that retailer.
- In that respect, we process your personal data:
- To facilitate commercial interactions between our company and your employer;
- For the security and safety of the website, our technology connected to the website and the users of the website;
- To detect and prevent fraud;
- To protect and defend the rights or property of others, or our own rights and interests;
- To manage and administer the website, including analyzing web traffic and utilizing web analytics solutions; and
- For use in marketing our products and services to your employer or affiliated entities.
- To provide content to the retailer’s website to enhance your shopping experience.
- Our legal obligations – we may need to process your personal data to comply with relevant laws, regulatory requirements and to respond to lawful requests, court orders and legal process.
Cookies and web analytics used on this website
The cookies we use can be categorized as follows:
|Strictly Necessary Cookies||These are cookies that are required for the operation of the website or of certain parts thereof. They either serve the sole purpose of carrying out network transmissions or are strictly necessary in order for us to provide an online service explicitly requested by you.
|Analytical/Performance Cookies||These cookies allow us to carry out web analytics or other forms of audience measuring such as recognizing and counting the number of visitors and seeing how visitors move around the website. This helps us to improve the way the website works, for example, by ensuring that users are easily finding what they are looking for.
|Functionality Cookies||These cookies are used to recognize you when you return to the website. This enables us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region). Loss of the information in these cookies may make our services less functional but would not prevent the website from working.
|Targeting/Profiling Cookies||These cookies record your visit to the website and/or your use of the services, the pages you have visited and the links you have followed. We will use this information to make the website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
The following cookies are used on retailer websites:
|Cookie Name||Who Places the Cookie?||Cookie Category||When Is Cookie Enabled/Does It Expire?||Purpose|
|Global Visitor ID||Flixmedia||Analytical /Performance/Targeting||Persistent for 1 year||Counting unique visitors on the retailer website and understanding and analysing shopper behaviour to improve shopper experience.|
|AB Testing||Flixmedia||Functionality||Persistent for up to 90 days
|Content testing for retailer websites|
|4 Session Cookies||Flixmedia||Strictly necessary||Session||Enabling Flixmedia content to appear on the retailer website in the least possible time to load. Used for syndication service.|
|2 Load balancer Session Cookies||Flixmedia||Strictly necessary||Session||Load balancer cookies, which are used to stick visitors to a particular server behind the load balancer and enable content to appear in the least possible time to load.|
The following cookies are used on the Flixmedia website:
|Cookie Name||Who Places the Cookie?||Cookie Category||When Is Cookie Enabled/Does It Expire?||Purpose|
|DYNSRV||Flixmedia||Strictly necessary||Session||WordPress uses these to control user content and editing rights|
|mf_user||Flixmedia||Strictly necessary||3 months||A cookie for checking if the user is new or returning|
|mf_8081*||Flixmedia||Strictly necessary||Session||A cookie for identifying the browser session.|
|PHPSESSID||Flixmedia||Strictly necessary||Session||WordPress uses these to control user content and editing rights|
|intercom-id||Intercom||Strictly necessary||6 months||Live chat plugin cookie|
The following web analytics are used on the retailer’s website:
|Analytics Type/Name||Who directs the Analytics?||Personal Data Processed by Solution||Does It Expire?||Purpose/Category|
|Flixmedia In House Analytics Tool||Flixmedia Limited||Information on your use of the Site, including, without limitation, your IP address||As per data retention policy||Evaluating your use of the Site, compiling reports for us on the impact produced by syndicated content and providing other services relating to website activity|
You may be receiving electronic communications as a result of being on our B2B marketing database. To provide newsletters or similar, we log and store your name, title, email address and company name. You can unsubscribe from these newsletters at any time by clicking the ‘unsubscribe from this list’ link at the bottom of the email or by sending us an email to firstname.lastname@example.org.
Recipients of your personal data
For the following purposes, we disclose your personal data to the following third parties, as required or permitted by applicable law:
|Who Is your Personal Data Disclosed To?||What Is the Purpose Underlying the Disclosure?|
|Companies affiliated with [Company], Inc. including:
|Third-party suppliers and service providers including:
· Salesforce (https://www.salesforce.com/)
· AspectWorks (http://www.aspectworks.com/)
· GSuite (https://gsuite.google.com/)
· Mailchimp (https://mailchimp.com/)
To enable B2B contact regarding Flixmedia products and services
To communicate with Flixmedia website chat users
To communicate with users of the Flixmedia website ‘Get In Touch’ form
To manage product and service related cases
To manage B2B documents such as contracts, project plans
To manage B2B marketing communications
|Flximedia Product Users
· Rackspace (https://www.rackspace.com/)
· AWS (https://aws.amazon.com/)
· Hetzner (https://www.hetzner.com/)
|To provide Flixmedia customers access to operational syndication and reporting systems
|Retail Website Users
· Limelight Networks (https://www.limelight.com/)
· JW Player (https://www.jwplayer.com/)
|To provide content (such as images, videos, specifications, descriptions) on the retailer’s website|
|To other third parties in line with applicable legal requirements (where applicable)||To comply with legal obligations that we are subject to;|
Data transfers to recipients outside of the European Economic Area
We may transfer your data to affiliated companies or third party service providers located outside the European Economic Area (“EEA”) in jurisdictions that are not subject to an adequacy decision by the EU Commission finding them to provide an adequate level of protection of personal data, i.e. a level of protection of fundamental rights and freedoms that is essentially equivalent to that guaranteed within the EU.
However, to ensure an adequate level of protection for your personal data, we will comply, and require the compliance of our third party providers, with one of the transfer mechanisms specified in the GDPR and approved by the EU Commission. You can ask for a copy of such appropriate safeguards by contacting the Flixmedia Data Protection Officer at email@example.com or +44 (0)208 358 3340 .
How long we keep your personal data
We have implemented appropriate retention periods for your personal data collected or otherwise processed on or through the website as set forth in our data retention policy. Where our processing of your personal data is based on legitimate interests or compliance with legal obligations, it will be deleted as soon as the underlying purpose has expired. We may retain your personal information for longer periods if it is subject to legal requirements such as government reporting or fraud prevention which we are required to observe. Personal data processed based on your consent, which is intended to be processed for the duration of your association or relationship with the company will be deleted in accordance with the above principles, or earlier if and when you withdraw your consent to continued processing.
Your rights regarding the processing of your personal data under the GDPR
European Union citizens and residents have the following rights under GDPR:
- inquire whether and what kind of personal data we hold about you and how it is processed, and to access or request copies of such personal data
- request the correction or supplementation of personal data about you that is inaccurate, incomplete or out-of-date in light of the purposes underlying the processing, or to
- obtain the erasure of personal data no longer necessary for the purposes underlying the processing, processed based on withdrawn consent, processed for legitimate interests that, in the context of your objection, do not prove to be compelling, or processed in non‑compliance with applicable legal requirements.
In addition, you have, subject to the conditions set out in the applicable law and without limitation, the rights to:
- request us to restrict the processing of personal data in certain situations where you feel its processing is inappropriate,
- object, in certain circumstances, to the processing of personal data for legitimate interests, and to
- request portability of personal data that you have actively or passively provided to us (which does not include data derived or inferred from the collected data), where the processing of such personal Data is based on consent or a contract with you and is carried out by automated means.
If you desire to exercise any of the rights indicated above, you must provide the requested information in the Data Subject Rights Request (DSRR) Form found here
There is no fee for a Subject Access Request, however, your request must be reasonable and proportional as to not overburden the organization with overly broad requests that would be financially prohibitive to address.
Your provision of personal data to us
Your use of the Flixmedia website, retailer website and electronic communication methods and your provision of personal data to us in the process is purely voluntary on your part. Subject to your sole discretion, you can, at any point, stop using the website or, where applicable, opt out of certain data processing operations while on the website or in electronic communications as described in this policy. An exception applies if and to the extent that you want to enter into or perform a contract with us through electronic communications. In this event, providing us with your related personal data is necessary for us to be able to enter into the contract with or provide any contractual services to you.
How we protect your personal data
We are committed to ensuring the security of your personal data. We take appropriate commercially reasonable technical, physical and organizational measures to prevent unauthorized or unlawful processing of your personal data or accidental loss or destruction of your personal data.
Changes to this notice
Flixmedia reserves the right in its sole discretion to amend this policy from time to time. In this event, we will post the revised policy on the website. We encourage you to periodically view this policy so that you remain informed as to how we are protecting users’ personal data and about what cookies are used on the website. We may, where necessary, notify users of any modified version of this policy that might materially affect the way we use, disclose or otherwise process users’ personal data or otherwise affect their privacy rights. We may do this by posting an update on the website which users will see at their next visit.
Contact us or our Data Protection Officer
- Flixmedia Limited, Unit 1, The Technology Park, Colindeep Lane, London. NW9 6BX. United Kingdom
- Flixmedia Data Protection Office
- +44 (0)208 358 3340
You also have the right to complain to the UK Data Protection Authority the ICO, the contact details are:
The Information Commissioner’s Office Water Lane, Wycliffe House Wilmslow – Cheshire SK9 5AF Tel. +44 1625 545 745 e-mail: firstname.lastname@example.org Website: https://ico.org.uk