This is the privacy notice of Penultimate Media Limited.

We respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

1. WHO WE ARE AND IMPORTANT INFORMATION What is the purpose of this privacy notice?

This privacy notice aims to give you information on how we collect and process your personal data through your use of this website, including any data you may provide through this website when you submit an enquiry using the contact form.

This website is not intended for children and we do not knowingly collect data relating to children.

You must read this privacy notice together with any other privacy 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 notice supplements the other notices and is not intended to override them.

Data controller(s)

Penultimate Media Limited is the controller and responsible for your personal data (collectively referred to as “Penultimate Media", "we", "us" or "our" in this privacy notice). Our contact details are 12 Green Avenue, Chellaston, Derby DE73 6TE - info@penultimatemedia.com - +44 (0) 7916 168570. For all data matters contact Peter Nulty (the company Director) on +44 (0) 7916 168570.

Penultimate Media Limited is the controller and responsible for this website.

Third-party links outside of our control

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.

2. THE PERSONAL DATA WE COLLECT ABOUT YOU

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioners Office.

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

• Identity Data including full name and title.
• Contact Data including home and business addresses, email address and telephone numbers.
• Profile Data including usernames and passwords.
• Marketing and Communications Data including your preferences in receiving marketing communications.

We also collect, use and share aggregated data through Google Analytics such as statistical or demographic data for any purpose. Aggregated data may be derived from your personal data when using this website but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific page or section of this website. 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 notice.

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.

If you fail to provide personal data

Where we need to collect your 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.

3. HOW WE COLLECT YOUR PERSONAL DATA

We use different methods to collect data from and about you including through:

Directly - You may give us your Identity, Contact, Profile and Marketing & Communications data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

• Contact us about our services;
• Enter into a contract with us so we can provide our services to you or your company or organisation;
• Request marketing and information about our services to be sent to you;
• Request a proposal or quotation for our services to be sent to you.
• Submit an enquiry through the contact form on our website or when you report a problem with our website.

Third parties or publicly available sources - We may receive personal data about you from various third parties and public sources as set out below:

• Search information providers such as Google based inside OR outside the EU;
• Identity and Contact Data from publicly availably sources such as Companies House and the Electoral Register based inside the EU.

4. HOW WE USE YOUR PERSONAL DATA

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

• Performance of Contract this means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
• Legitimate Interest this means the interest of our business in conducting and managing our business to enable us to give you the best service and the most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting Peter Nulty (the company Director) at info@penultimatemedia.com.
• Comply with a legal or regulatory obligation this means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.

Generally we do not rely on consent as a legal basis for processing your personal data other than in relation to sending direct marketing communications to you via email. You have the right to withdraw consent to marketing communications at any time by contacting Peter Nulty (the company Director) at info@penultimatemedia.com.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA

We have set out below, a description of all the ways we use your personal data, with the legal bases we rely on to do so.

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 Peter Nulty (the company Director) at info@penultimatemedia.com if you need details about the specific legal ground we are relying on to process your personal data.

4.1. Performance of Contract:

• To engage with you as a client;
• To provide and carry out our services;
• To manage our relationship with you when carrying out our services.

4.2. Legitimate Interest:

• To update and maintain our records;
• For managing and auditing our business operations;
• To send you marketing emails about our services.

4.3. Comply with a legal or regulatory obligation:

• When you exercise your rights under data protection law and make requests;
• For compliance with legal and regulatory requirements including maintaining our company accounts;
• To notify you about changes to our terms and conditions, privacy policy and other legal or regulatory requirements.

Marketing

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

Promotional offers from us

We may use your Identity, Contact, Profile and Marketing & Communications data 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 services and offers may be relevant for you.

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

Third-party marketing

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

Opting out

You can ask us to stop sending you marketing emails at any time by following the opt-out links on any marketing email sent to you or by contacting info@penultimatemedia.com at any time.

Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see the cookie policy on this website.

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 Peter Nulty (the company Director) by email at info@penultimatemedia.com.

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.

5. WHO WE SHARE YOUR PERSONAL DATA WITH

We may have to share your personal data with the parties set out below for the purposes set out in section 4 above.

Internal Third Parties:

• Subcontractors who provide professional services to Penultimate Media. We will only share personal data with subcontractors where it is necessary for the performance of a contract with you;
• Companies and other persons who provide products or services to us necessary for the provision of our services to you.

External Third Parties:

• Professional advisers including lawyers and accountants who provide legal and accounting services;
• HM Revenue & Customs, regulators and other authorities acting as processors based in the United Kingdom who require reporting of processing activities in certain circumstances;
• Other parties authorised by you.

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.

6. INTERNATIONAL TRANSFERS

We do not transfer your personal data outside the European Economic Area (EEA).

7. 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.

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.

8. DATA RETENTION

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the provision of our services to you, for updating and maintaining our business records and 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.

By law we have to keep basic information about our customers including identity and contact data for six years after they cease being customers for tax and record keeping purposes.

In some circumstances you can ask us to delete your data: see Your legal rights below for further information.

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.

9. YOUR LEGAL RIGHTS

Unless subject to an exemption under the data protection laws, you have the following rights with respect to your personal data:

• The right to request a copy of the personal data which we hold about you;
• The right to request that we correct any personal data if it is found to be inaccurate or out of date;
• The right to request your personal data is erased where it is no longer necessary to retain such data;
• The right to withdraw your consent to the processing at any time, where consent was the lawful basis for processing your data;
• The right to request that we provide you with your personal data and where possible, to transmit that data directly to another data controller, (known as the right to data portability), where applicable i.e. where our processing is based on consent or is necessary for the performance of a contract with you or where we process your data by automated means;
• The right to object to our processing of personal data, where applicable i.e. where processing is based on our legitimate interests (or in performance of a task in the public interest/exercise of official authority); direct marketing or processing for the purposes of scientific/historical research and statistics.

If you wish to exercise any of the rights set out above, please contact Peter Nulty (the company Director) by email at info@penultimatemedia.com.

No fee required – with some exceptions

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 admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

What we may need from you

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.

Time limit to respond

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.

10. Changes to this notice and your duty to inform us of changes

This version was last updated on 19th May 2018.

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

11. Queries, requests or concerns

To exercise all relevant rights, queries or complaints in relation to this policy or any other data protection matter between you and us, please in the first instance contact Peter Nulty (the company Director) by email at info@penultimatemedia.com or by telephone on +44 (0) 7916 168570.

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioners Office on 03031231113 or via email https://ico.org.uk/global/contact-us/email/ or at the Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF, England, UK.

Cookies & This Website

This site uses cookies - small text files that are placed on your machine to help the site provide a better user experience. In general, cookies are used to retain user preferences, store information for things like shopping carts, and provide anonymised tracking data to third party applications like Google Analytics. As a rule, cookies will make your browsing experience better. However, you may prefer to disable cookies on this site and on others. The most effective way to do this is to disable cookies in your browser. We suggest consulting the Help section of your browser or taking a look at the About Cookies website which offers guidance for all modern browsers.

Website Disclaimer

The information contained in this website is for general information purposes only. The information is provided by Penultimate Media Limited and while we endeavour to keep the information up to date and correct, we make no representations or warranties of any kind, express or implied, about the completeness, accuracy, reliability, suitability or availability with respect to the website or the information, products, services, or related graphics or photographs contained on the website for any purpose. Any reliance you place on such information is therefore strictly at your own risk.

In no event will we be liable for any loss or damage including without limitation, indirect or consequential loss or damage, or any loss or damage whatsoever arising from loss of data or profits arising out of, or in connection with, the use of this website.

Through this website you are able to link to other websites which are not under the control of Penultimate Media Limited. We have no control over the nature, content and availability of those sites. The inclusion of any links does not necessarily imply a recommendation or endorse the views expressed within them.

Every effort is made to keep the website up and running smoothly. However, Penultimate Media Limited takes no responsibility for, and will not be liable for, the website being temporarily unavailable due to technical issues beyond our control. There is no guarantee that the website will be available on a consistent or ongoing basis, and the provision of this website may be subject to periods of interruption or poor performance and may be terminated at any time. This website may not be compatible with the web browser or other software you use.

Your use of this website is at your own risk, and it is your responsibility to take precautions to ensure that the pages and other materials are free from viruses, worms, trojan horses or other items of a destructive nature.

Website Terms & Conditions

Welcome to our website. If you use this website, you are agreeing to comply with and be bound by the following terms and conditions of use, which together with our cookie policy and disclaimer govern Penultimate Media's relationship with you in relation to this website and any products or services offered through it. If you disagree with any part of these terms and conditions, please do not use our website.

The term 'Penultimate Media' or 'us' or 'we' or 'our' refers to Penultimate Media Limited who is the owner of the website. The term 'you' refers to the user or viewer of this website.

The use of this website is subject to the following terms of use:

• The content of this website is for your general information and use only. It is subject to change without notice.
• Neither we nor any third parties provide any warranty or guarantee as to the accuracy, timeliness, performance, completeness or suitability of the information, materials, products and services found or offered on this website for any particular purpose. You acknowledge that such information, materials, products and services may contain inaccuracies or errors and we expressly exclude liability for any such inaccuracies or errors to the fullest extent permitted by law.
• Your use of any information or materials on this website or any products and services offered through this website is entirely at your own risk, for which we shall not be liable. It shall be your own responsibility to ensure that any information, materials, products and services available through this website meet your specific requirements.
• This website contains material which is owned by or licensed to us. This material includes, but is not limited to, the design, layout, look, appearance, graphics and photographs. Reproduction is prohibited other than in accordance with the copyright notice below, which forms part of these terms and conditions.
• Unauthorised use of this website may give rise to a claim for damages and/or be a criminal offence.
• From time to time, this website may also include links to other websites. These links are provided for your convenience to provide further information. They do not signify that we endorse the website(s). We have no responsibility for the content of the linked website(s).
• Your use of this website and any dispute arising out of such use of the website is subject to the laws of England and Wales.
• If all or any part of these terms and conditions is found to be void or unenforceable for any reason, that part of the terms and conditions shall, where possible, be severed from the whole and the rest of the terms and conditions shall remain valid and enforceable. The same applies to the disclaimer and cookie policy contained on this website.

Free Website and Social Media Audit

• The website part of the free audit will be carried out by Penultimate Media Limited. The social media part of the free audit will be carried out by Social Media 365, a separate business entity to Penultimate Media Limited.
• Penultimate Media and Social Media 365 are separate business entities working together to provide this service.
• The offer laid out in this website of a free website and social media audit does not form a contract, engagement or agreement between Penultimate Media, Social Media 365 and you.
• It shall be at Penultimate Media's and Social Media 365's sole discretion as to whether or not to engage with you and carry out the free website and social media audit after you have enquired about the service. Penultimate Media and Social Media 365 reserve the right to refuse to carry out the free website and social media audit and are under no obligation to carry out the audit after you have enquired.
• If the free audit is carried out the total of Penultimate Media's and Social Media 365's obligations to you will be the free website and social media audit only.
• Should you wish to act on any of the recommendations in the free audit or engage with either business for other products or services, this will be charged either as a fixed cost project or at Penultimate Media's and Social Media 365's standard billable rates and will require your agreement to a payment schedule, statement of work and terms and conditions prior to commencement of any work by either business.
• Penultimate Media and Social Media 365 reserve the right to withdraw this offer at any time.

Email Communications

Penultimate Media Limited does not accept legal responsibility for any confidential information that may be sent to it by you from this website or by you sending any other message to Penultimate Media Limited over the Internet.

Please note therefore that any information sent to Penultimate Media Limited over the Internet will be sent at your own personal risk. Internet communications may not be secure. Penultimate Media Limited recommends that you do not send any confidential information to it over the Internet unless it is sent by some secure method of transmission using appropriate encryption technology.

Copyright Notice

This website and its content is copyright of Penultimate Media Limited – © Penultimate Media Limited 2017. All rights reserved.

Any redistribution or reproduction of part or all of the contents in any form is prohibited other than the following:

• You may print or download to a local hard disk extracts for your personal and non-commercial use only.

You may not, except with our express written permission, distribute or commercially exploit the content. Nor may you transmit it or store it in any other website or other form of electronic retrieval system.