Data Protection Policy Let's go! Vox data protection transparency notice for clients, suppliers and other third parties. Vox (we) is the trading name of Vox Media, limited company registered in England and Wales under number 05197361 with registered office at 85 Fleet Street, London EC4Y 1AE. 1. What is the purpose of this document? 1.1 This transparency notice describes how we collect and use your personal information during and after your relationship with us. We are a “controller”, which means that we are responsible for deciding how we hold and use personal information about you and explaining it clearly to you. 1.2 This notice applies to users of our website, individuals at clients and suppliers, prospective clients, journalists and individuals included in promotional videos made for us or our clients (you). It is important that you read this notice, together with any other transparency notice we may provide on specific occasions when we are collecting or processing personal information about you, so that you are aware of how and why we are using such information. We reserve the right to update this transparency notice at any time and it is up to you to check that you have read the most up-to-date notice. 1.3 If you have any queries about this transparency notice or how we handle your personal information, please contact: firstname.lastname@example.org 2. Third party links 2.1 Our 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 transparency statements. When you leave our website, we encourage you to read the privacy or transparency notice of every website you visit. 3. How do we collect information about you? 3.1 We collect personal information directly from you when you visit our website, communicate with us directly, or take part in videos that we make. 3.2 We collect personal information about you indirectly from our clients, suppliers or other industry professionals. 3.3 We may collect information about you from public sources, including social media sites such as LinkedIn. 4. What information do we hold? 4.1 We collect, store and use your personal information including: your name; contact details including email address, telephone number, work address; job title and location; biographical information; contents of interview recordings, film footage and voiceovers; and any other information that is necessary to maintain our relationship with you. 5. What are the legal bases for us to use your personal information? 5.1 We will only use your personal information when the law allows us to. Most commonly, we will use your personal information in the following circumstances: 5.1.1 where we need to perform the contract we have entered into with you; 5.1.2 where we need to comply with a legal obligation; and 5.1.3 where it is necessary for our for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are to ensure the smooth running of our business; providing services to our clients; and managing our relationships with and for our clients. 6. For what purposes do we use your personal information? 6.1 We may use your personal information for the following purpose: 6.1.1 to carry out obligations arising from any contracts between us and you, with clients, suppliers or third parties; 6.1.2 to communicate with you, including to provide you with information about our services; 6.1.3 to create promotional videos for us or our clients that will feature you; 6.1.4 to invite you to events and briefings that we run for our clients; 6.1.5 to put clients in touch with journalists or other industry professionals; 6.1.6 where it is necessary for our clients’ businesses or our business. 7. Change of purpose 7.1 We will only use your personal information 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 we need to use your personal information for an unrelated purpose, we will inform you and we will explain the legal basis which allows us to do so. 7.2 Please note that we may process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law. 8. Data sharing 8.1 We will share your personal information with third parties where required by law, where it is necessary to administer the working relationship with you or where we have another legitimate interest in doing so (including when we provide our clients with their promotional videos). 8.2 We share our promotional videos in which you have featured with Vimeo, in order to share our videos with our clients. These promotional videos are not available for general viewing and are only accessible to the individuals to whom we send the security details. 8.3 We may share our promotional videos in which you have featured on our website as a ‘Case Study’. 8.4 We may also share the promotional videos that you have featured in with our clients and prospective clients when delivering pitches. 8.5 Where we share information with other controllers, they are responsible to you for their use of your information and compliance with the law. We share information with other controllers as follows: our clients; suppliers; journalists; Tulchan Communications LLP and Briefcase. News Limited (together the “Tulchan Group”); industry professionals; regulatory bodies; and professional advisors. 8.6 We may share your personal information with third party service providers on our behalf such as IT services providers. All our third party service providers and Tulchan Group are required to take appropriate security measures to protect your personal information in line with our policies. We do not allow our third party service providers to use your personal information for their own purposes. 9. Data security 9.1 We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. We have put in place procedures to deal with any suspected data security breach and will inform you and any applicable regulator of a suspected breach where we are legally required to do so. 10. How long do we use your information for? 10.1 We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 10.2 To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorised use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements. 10.3 We keep promotional videos in which you have featured for as long as we have a legitimate interest in doing so, provided your interests and fundamental rights do not override those interests. 11. Your rights in connection with personal information 11.1 You have the right to object to any use of your personal information which is not necessary for the performance of a contract between you and us, unless we have there are compelling legitimate grounds which override your interests, or we are acting pursuant to a legal obligation. 11.2 You also have the right to restrict the processing of your personal information (in limited circumstances), access, amend, erase or receive a copy of your personal information in a portable form to the extent permitted by law. 11.3 You have the right to contact a data protection authority if you have unresolved complaints. The UK regulator, the Information Commissioner’s Office, can be found at: ico.org.uk. 11.4 To exercise any of the above rights, please contact email@example.com. We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights).