Flywheel by Ascential Privacy Notice
We are committed to protecting and respecting your privacy. We hold, as with most businesses, personal information about our customers and people who may be interested in our products and services.
This Privacy Notice explains the type of information processed by the Flywheel by Ascential companies, how that processing may affect you and your rights. This Privacy Notice was last updated on January 18, 2019.
We will occasionally update this Privacy Notice. We will post a notice of any material changes on our website prior to implementing the changes, and, where appropriate, notify you using any of the contact details we hold for you for this purpose. We encourage you to periodically review our policies to be informed of how we use your information.
Our Data Protection Officer can be contacted at DPO@ascential.com. Any questions regarding this notice and our privacy practices should be submitted through www.ascential.com/data or by writing to Legal Director, Flywheel by Ascential, c/o Ascential Group Limited, The Prow, 1 Wilder Walk, London, United Kingdom, W1B 5AP.
If you wish to make a complaint about how we use your information, please submit it through the following website www.ascential.com/data and we will do our best to help. If you are still unhappy, you can contact the appropriate data protection supervisory authority. The UK Information Commissioner’s Office can be contacted via their website
Please see the Definitions section for definitions of terminology used in this Privacy Notice.
This Privacy Notice applies to the processing of personal data, including information we collect and store via cookies, as explained below.
References in this policy to “we” “us” or “our” should be interpreted in accordance with the above.
Flywheel by Ascential – Europe and Flywheel by Ascential – U.S. are Ascential Plc companies. Note that if you access the products and services of other Ascential companies, you should refer to their Privacy Notices.
Information We Collect
Collection directly from you
Most of the personal data we process about you comes directly from you for example:
- when you contact us (by email, phone, mail or in person);
- when you become a designated contact and/or an authorised user on one of our platforms; and/or,
- when you express an interest in our products and services.
Please note that we may record conversations made with our Account Managers.
Automatic collection when you contact us or visit our website (Cookies Policy)
We automatically collect information about you as follows:
When you visit a Flywheel by Ascential website, we may use “cookie” technology try to make that experience simple, personalised and meaningful. Cookies are small pieces of information which are issued to your computer or any similar device you use to access the internet e.g. smart phone, tablet or other mobile device when you visit a website and which store and sometimes track information about your use of the website. A number of cookies we use last only for the duration of your web session and expire when you close your browser. Other cookies are used to remember you when you return to the website and will last for longer.
- create a specific log-in session for a visitor to a Flywheel by Ascential website in order that page requests by that visitor are delivered in an effective, secure and consistent manner;
- recognise when a visitor to a Flywheel by Ascential website has visited before; this means we can identify the number of unique visitors we receive to the website and allows us to make sure we have enough capacity for the number of users that we get;
- customise elements and/or content of the pages of the website; and,
- collect statistical information about how our visitors use the website(s) so that we can improve the website(s) and learn which parts are most popular to visitors.
Some of the cookies used by Flywheel by Ascential websites are set by us, and some are set by third parties who are delivering services on our behalf. Most web browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You can also learn more about cookies by visiting www.allaboutcookies.org which includes additional useful information on cookies and how to block cookies using different types of browser. Please note however, that by blocking or deleting cookies used on a Flywheel by Ascential website you may not be able to take full advantage of the website(s) if you do so.
In addition to cookies, tracking gifs may be set by us or third parties in respect of your use of the website(s). Tracking gifs are small image files within the content of our site or the body of our newsletters so we or third parties can understand which parts of the website are visited or whether particular content is of interest.
Information obtained from other sources
We may obtain publicly available professional information about you (as detailed in the Data Processed section below) from third parties or online publications. This information is used in the following ways:
- to ensure that the information we hold about you is accurate and up to date;
- to ensure that we have all the information we need to provide or offer you with a product or service; and
- to help us to provide the best service possible, in the most efficient manner.
Why we process your data
This section details the information what we collect, the purpose for its collection and use, and the legal basis for the processing.
|Purpose||Personal Data||Processing Ground|
|To provide you with Flywheel by Ascential products and services.||
||Performance of a Contract.|
|To respond to your communications and to retain a record for quaility and training purposes.||
||Legitimate interest; or consent|
|To ensure network and information security.||
Web log server information:
|To monitor the performance of our website and improve user experience||Web log server information (see above)||Legitimate interest|
|To contact you or to stay in touch with you about your products and services.||
||Legitimate interest; or Consent or Soft opt-in|
|Informing our product and services strategy to enhance and personalise our customer experience and offerings. Informing our marketing strategy to ensure our communications with you are relevant.||
|To determine your interest in our products and services.||
1Where Legitimate Interest is the processing Ground, the legitimate interest is provided in the Purpose column.
Special Categories of Personal Data
We do not knowingly or intentionally collect special categories of personal data from individuals and we request that you please do not submit special categories of personal data to us.
How we share your data
We share your data in the manner and for the purposes described below:
- Flywheel by Ascential companies are part of Ascential Plc. We share information within with Ascential-controlled affiliates and subsidiaries, where such disclosure is necessary to provide you with our services or to manage our business. It is our legitimate interest to process your personal data for these purposes;
- with Ascential Plc controlled affiliates Media Link, LLC or MediaLink Europe Limited (collectively, “MediaLink”) where MediaLink is better able to provide you services of interest to you;
- with third parties who help manage our business and deliver services. These third parties have agreed to confidentiality restrictions and use any personal information we share with them or which they collect on our behalf solely for the purpose of providing the contracted service to us. These include: IT service providers, customer relationship management services and marketing automation, solutions and analytics providers;
- with third parties where you have given your consent;
- with our regulators, to comply with all applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies;
- we may share in aggregate, statistical form, non-personal information regarding the visitors to our website, traffic patterns, and website usage with our partners or affiliates; and
- if, in the future, we sell or transfer some or all of our business or assets to a third party, we may disclose information to a potential or actual third-party purchaser of our business or assets.
Explaining more about direct marketing and profilingHow we use personal information to keep you up to date with our products and services
We may use personal information to let you know about Flywheel by Ascential products and services that we believe will be of interest to you. We may contact you by email, post, or telephone or through other communication channels that we think you may find helpful. In all cases, we will respect your preferences for how you would like us to manage marketing activity with you.How you can manage your marketing preferences
To protect privacy rights and to ensure you have control over how we manage marketing with you:
- we will take steps to limit direct marketing to a reasonable and proportionate level and only send you communications which we believe may be of interest or relevance to you;
- you can ask us to stop direct marketing at any time - you can ask us to stop sending email marketing, by following the 'unsubscribe' link you will find on all the email marketing messages we send you. Alternatively, you can contact through the following website: www.ascential.com/data. Please specify whether you would like us to stop all forms of marketing or just a particular type (e.g. email); and
- you can change the way your browser manages cookies by following the settings on your browser.
In order to understand your interest in our products and services and/or to ensure that we only send you communications which we believe may be of interest or relevance to you we analyse your engagement with our website, content, products and services. For example, your level of engagement or a specific topic of engagement will lead us to infer what is of most interest to you and if you we may offer you similar further content or related services.
We retain your information for no longer than necessary for the purpose for which it was collected. In determining how long your information will be stored, we will consider:- the purpose(s) and use of your information both now and in the future;
- what information we need to:
- best provide you with products and services;
- manage your relationship with us;
- meet our statutory obligations;
- develop our products and services; and
- meet our customers’ and previous customers reasonable expectations.
Geographic Data Transfers
As a global organisation and as an Ascential Plc group company with a presence in more than 150 countries, we may transfer your personal data outside the EEA to provide the best service possible to our customers and in the most efficient manner. In all instances, we take steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognized as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights. To this end:
- we ensure inter-company transfers are covered by appropriate agreement(s) which contractually obliges each member to ensure that personal information receives an adequate and consistent level of protection wherever it is transferred within the Ascential Plc group;
- where we transfer your personal information outside the Ascential Plc group or to third parties who help provide our products and services, we obtain contractual commitments from them to protect your personal information. Some of these assurances are well recognized certification schemes like the EU - US Privacy Shield for the protection of personal information transferred from within the EU to the United States; or
- where we receive requests for information from law enforcement or regulators, we carefully validate these requests before any personal information are disclosed.
Data Subjects' Rights within the EEA
In the EEA, data subjects have the following rights:
- to request access to your information and information related to our use and processing of your information;
- to request the correction of your information (we may seek to verify the accuracy of the personal information before rectifying it);
- in certain situations, to ask us to erase, block or restrict the personal information we hold about you, or object to particular ways in which we are using your personal information; and
- in certain situations, you can also ask us to send the personal information you have given us to a third party.
- to ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the EEA.
- to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. This will not affect the lawfulness of our processing of your data prior to your withdrawal;
- to object to the processing of your information for certain purposes, namely:
- to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests;
- to object to us using or processing your information for direct marketing purposes. You may also exercise your right to object to us using or processing your information for direct marketing purposes by clicking the unsubscribe link contained at the bottom of any marketing email we send to you and updating your preferences, or as a subscriber by visiting the preference centre on our website and changing your preferences.
Legal Director, Flywheel by Ascential, c/o Ascential Group Limited, The Prow, 1 Wilder Walk, London, United Kingdom, W1B 5AP or by submitting your request to us at the following website www.ascential.com/data.
You have a right to lodge a complaint with your local supervisory authority if you have concerns about how we are processing your personal information. We ask that you please attempt to resolve any issues with us first, although you have a right to contact your supervisory authority at any time.
Data Subjects' Rights in California
If you are a resident of California you may have a right pursuant to Section 1798.83 of the California Civil Code to obtain certain information about the types of personal data that we have shared with third parties for direct marketing purposes during the preceding calendar year, including the names and addresses of those third parties, and examples of the types of services or products marketed by those third parties.
Please contact us at DPO@ascential.com if you would like to exercise any of your rights explained above in relation to your personal data.
Do not Track
Some browsers offer a “do not track” (“DNT”) option. For information about Do Not Track, please visit www.allaboutdnt.org.
At this time we do not respond to DNT signals.
Third Party Websites
Please be aware that we do not control and are not responsible for websites that are referred to or linked from its own websites and that use of your personal information on these websites is not subject to this Privacy Notice.
Persons 18 or under
We are concerned to protect the privacy of children. We do not knowingly contact or collect information from persons under the age of 18. The website is not intended to solicit information of any kind from persons under the age of 18.
If you believe that we have received information pertaining to or from persons under the age of 18 please contact us at DPO@Ascential.com. If we become aware that a person under the age of 18 has provided us with personal information, we will take steps to delete such information.
Compliance with a legal obligation - processing is necessary to ensure we comply with our legal and regulatory obligations.
Consent – you have given specific consent to the processing of your personal data.
Data Controller – the entity that determines the purposes and means of processing personal data.
EEA – the European Economic Area which comprises countries that are members of the European Union and Norway, Iceland and Liechtenstein.
Identifiable natural person - a person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
Legitimate Interests - processing is necessary for our or a third party’s legitimate interests in carrying on, managing and administering our respective businesses effectively and properly (except where our or the third party’s interests are overridden by your own interests, rights and freedoms).
Performance of a Contract – processing is necessary to carry out our contractual duties, exercise our contractual rights or otherwise perform our Contract with you, or to take steps at your request to enter a Contract.
Personal Data - any data relating to an identified or Identifiable Natural Person.
Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Special categories of personal data - personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric data processed for the purpose of uniquely identifying a natural person, data concerning Vital Interests – processing necessary protect an interest which is essential for the life of the data subject or that of another natural person.