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Privacy notice

Last updated 18th February 2023

This privacy notice explains how we, base® (a registered mark and trading name of base media cloud limited, of Mercury House, 117 Waterloo Road, London, SE1 8UL) and other brands we may own and operate at any time (collectively, “base®”, “we”, “us”, “our”) process your personal data (“you”, “your”) when you interact with our website, newsletter or other sales and marketing related online services. base® is the controller of your personal data for the purposes of web marketing. Existing Customer Notice: This Privacy Notice is separate to any Data Processing Agreement and Privacy Policy terms relating to our specific Service Agreement(s) terms for cloud services held by our customers and is strictly related to digital sales and marketing interactions.

1. Purpose of this privacy notice

  • This privacy notice aims to give you information on how base® collects, uses, discloses, transfers, stores and processes your information when you interact with our website, newsletter any other sales and marketing related online or digital services, including any data you may provide through your use of our services.
  • It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing information 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.
  • If you have any questions about this privacy notice, please contact us using the details set out at the end of this notice.

2. Who does this privacy notice apply to?

This notice applies to:
  • Our service users, website visitors, newsletter recipients and any other party who receives or interacts with sales and marketing related digital materials under our control, including users who watch our promotional video content, download our marketing materials, submit messages or content to us, participate in our surveys, digital events, focus groups and other related interactions;
  • Our clients, suppliers, business contacts and partners; and
  • Other persons who interact with us when you call us, email or raise a digital communication message with us (including via our online support desk).
This notice applies to you whether you act in your personal capacity or as employee or agent of an organisation.

3. What types of information do we collect?

Generally, “personal information”, “personal data” or similar terms refer to any information that identifies you or relates to you. However, the exact meaning of personal information may be determined by the law of the country of your residence. We will process the following personal data about you, depending on the type of interaction you have online with any of our digital sales and marketing platforms or activities:

  • Your contact details such as your name and email address when you sign up to our newsletter as a user or engage with our focus groups or surveys or other downloadable or gated online content. When you interact with us in your business capacity, we may ask for your name, role, employer details, telephone number, email address and similar information.
  • When you contact or visit us, we may process your enquiry, communication, complaint and other details of your enquiry.
  • If you are a prospective client, we will keep your personal and professional details and other opportunity records for sales purposes.
  • If you engage with our focus groups or surveys, or software beta and testing programmes, we will collect your input and other participation information. We will usually aggregate this data so that this data does not directly or indirectly reveal your identity or any special category data.
  • If you participate in our events or partner events to which we are legitimate sponsors with rights to pre-approved attendees lists containing your personal information, we collect your contact details such as your name, email address, job role, phone number and company details. This data is used for the purposes of the relevant event communications and addition to our mailing list for relevant follow-up communications, should you select and permit such option. If we share your data with third party partners, such as a base® technology partner that has sponsored an event, we will tell you this when you sign up.
  • Your direct marketing preferences. For example, we may send you an email if you opt in to receive marketing communications.
  • When we send you emails or other communications or if you interact with our content all over the Internet we may collect engagement information such as open rates, click rates, view rates, active time spent, site journeys and similar information, which in most cases is logged anonymously and only used for aggregated web marketing performance data.
  • When accessing our services, your device and browser will automatically provide unique information such as mobile device ID, internet protocol (IP) address, cookie ID or online identifiers, operating system, browser type, time zone setting, location and date and time of access.
  • Our website may record website usage data about how you navigate and engage with our services, use our features, download materials, security logs will be kept, online activity data such as clickstream data with URLs visited previously, page interaction information (such as scrolling, clicks, and mouse-overs), your preferences (including country and language), and methods used to browse away from our website. We may collect data through platforms including Google subject to your cookie consent settings.
  • When you access our website or content, we may collect information about your base® solution preferences and interests known, observed or inferred which we may use for personalisation and direct marketing which we believe will be relevant and of interest to you.
  • Social media profile details including your social media username, name, profile photo and any other information you choose to make available to us when you connect with or contact us through your social media account or access our content via your social media account (including, for example: Linkedin).
  • Third party data about you such as information about your interaction with our posts and content and ‘likes’ on social media platforms, such as Facebook, Twitter, Snap, TikTok, or LinkedIn, profile information, preferences and interests received from our advertising and analytics partners and other third parties.

Much of the personal data is provided by you or automatically by your device. You can adjust your device privacy settings to limit disclosure of your personal data that is not necessary for our digital marketing interaction and online services.
We would ask that you only provide the necessary personal data to us and take responsibility for your own device and browser settings.
Some of the information will be necessary to assist you, share information or to provide our services or to pursue our legitimate interests in data processing. In certain limited cases, some personal data may be mandatory for our compliance with the law.

4. Data accuracy

We will rely on the information provided by you as accurate, complete and up to date, so please keep us informed of any changes. For example, if you change your email address, please let us know so that we can continue sending you our newsletters and other useful updates.

5. What information do we collect and why?

Generally, we will use your personal data to (i) provide and enable you to use and interact with our website, online sales and marketing content and other online services, (ii) respond to your queries, (iii) develop and promote our organisation and services; (iv) ensure the security and technical availability of our services; and (v) comply with the law.

Purpose
Personal data
Legal ground for processing (for individuals in the EEA, Switzerland and UK only)
Purpose:

To assist and contact you in relation to your enquiry.

Personal data:

Contact details  

Details of your enquiry

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in responding to queries, developing business relationships and administering our business or to take necessary steps at your request prior to entering into a contract with you.

Purpose:

To provide our services to you, such as our website, online content and other online services.

Personal data:

Device & browser data

Engagement information

Website usage data  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in providing our website and content to you or, as the case may be, necessary for the performance of our contract with you.

Purpose:

To provide our services to you, such as our website, online content and other online services.

Personal data:

Contact details

Opportunity records

Preferences and interests

Engagement information  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in understanding and maintaining our business relationships and administering our business.

Purpose:

To send you information which you have requested about our services and service communications about matters relevant to your use of our services and your engagement with us, such as changes in our terms, events, etc.

Personal data:

Contact details

Preferences and interests

Engagement information   

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Service communications are necessary for the performance of our contract with you. Other notifications are necessary for our legitimate interest in satisfying your requests, facilitating our services and organising related business activities.

Purpose:

To engage with you about surveys, focus groups and software assessment (beta) programmes.

Personal data:

Contact details

Preferences and interests

Engagement information

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

We will obtain your consent where required by law. Necessary for our legitimate interest in developing our business and organising related business activities.

Purpose:

To send you our newsletter and promotional information through email about our services and organisation, reviewing and optimising campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.

Personal data:

Contact details

Preferences and interests

Engagement information

Third party data

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

We may rely on soft opt-in to send marketing to our existing clients or will obtain your consent as required by law, for example, if you sign up for our newsletter or sign a Service Agreement containing such terms as to allow our contact with Customer users.

Some of our direct marketing activities are necessary for our legitimate interest in understanding your interests from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics.

Purpose:

To display advertisements relevant to you on websites and social media, reviewing and optimising campaign performance and profiling information about your interests known, observed or inferred for direct marketing purposes.

For example, we use your contact details to display relevant ads through LinkedIn or other social media platforms.  Social media and advertising providers may use their own information about you to help us make our ads more relevant.

Personal data:

Contact details

Engagement information

Preferences and interests

Third party data

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

We will obtain your consent where required by law. For example, your consent will be required to place cookies or similar technologies on your device or to read information on your device.

Some of our direct marketing activities are necessary for our legitimate interest in understanding your interests from the information available to us, information observed or inferred and third party information, in promoting our business and understanding campaign metrics.

Purpose:

To improve and develop our services, including to:  
• obtain feedback;
• use partners including Google Analytics to understand the demographics and geographies of our users and for leads measurement;
• conduct statistical analysis;
• make services and features more relevant;
• improve user experience;
• work with third parties and evaluate data to improve and develop our services.

Personal data:

Aggregated data based on your participation information, engagement information, device & browser data, website usage data and preferences and interests.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in delivering our services properly, efficiently and understanding our customer’s needs and expectations.

We will use cookies and similar technologies if you provided your consent.

Purpose:

To ensure proper administration of our business, including to:  
• keep appropriate records about how our services are used;
• resolve complaints;
• conduct troubleshooting; • provide customer support;
• manage our business relationships and identify opportunities;
• register interactions with our communications, such as emails and web form enquiries;
• enforce our terms; and
• conduct billing and debt collection.

Personal data:

All information as is necessary and proportionate for the administration of our business.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in the proper administration of our business, dispute resolution, ensuring technical operation of our services and debt collection and necessary for compliance with a legal obligation to which we are subject.

Purpose:

To facilitate purchases, when made online, e.g. via an online base® marketplace or by way of PayPal or other integrated payment gateway service. Payment information will be processed by an approved, industry standard and secure online transaction software system. Such payment data is encrypted.

Personal data:

Contact details

including address and email address

payment information  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for the performance of our contract with you, should you procure our services via an online payment mechanism.

Purpose:

To engage our third party service providers who may process your information on our behalf to facilitate the provision of our services and the fulfilment of essential service functions, such as web hosting, Software-as-a-Service components, cloud storage, analytics, payments, order fulfilment, plugins, communications, accounting, security and others.

Personal data:

All information as is necessary and proportionate to enable the relevant service to be provided to you.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Some activities are necessary for the performance of our contract with you, others are necessary for our legitimate interest in ensuring the proper operation of our services.

Purpose:

To monitor our networks, website and systems for suspicious activities, test and audit our systems and deploy appropriate security measures.

Personal data:

Website usage data, device and browser data.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest to ensure the security of our organisation, people and services and necessary for compliance with a legal obligation to which we are subject.

Purpose:

To monitor interactions and operations for fraud prevention and crime detection purposes, including information from third parties who may help us verify your identity or alert us about suspicious activities.

Personal data:

Contact details, browser and device data, website usage data, third party data.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in detecting and preventing fraud and illegal conduct and necessary for compliance with a legal obligation to which we are subject.

Purpose:

To process health information provided by you, inform you of government guidance and, where appropriate, inform third parties about the risk of infection or share information with relevant authorities (for example, regarding COVID-19 safe events).

Personal data:

Health information provided by you.

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws, and where necessary for compliance with a legal obligation to which we are subject, or to establish, exercise or defend legal claims or to fulfil our duty of care owed to third parties.

Purpose:

To share information with our affiliated companies and sub-processors, each of which will be subject to the same strict operating procedures around data protection, data privacy and data security.

Personal data:

All information as is necessary and proportionate.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in using our group’s resources to organise, develop and deliver our services, run our organisation and decide on future strategies.

Purpose:

To share data with another organisation in accordance with the law for the purposes of a joint venture, collaboration, financing, sale, merger, reorganisation or similar event relating to our business.

Personal data:

All information as is necessary and proportionate in connection with the event.  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.

Purpose:

To process information as is required for our compliance with the law or to establish, exercise or defend legal claims. To process and share information with other third parties where required by law, such as regulators, law enforcement agencies or where mandatory under a court order.

Personal data:

Any information subject to mandatory processing or disclosure, where this is necessary and proportionate  

Legal ground for processing (for individuals in the EEA, Switzerland and UK only);

Where processing or sharing your data is necessary for compliance with a legal obligation to which we are subject, to establish, exercise or defend legal claims, or, where necessary and proportionate, in order to satisfy our legitimate interest in complying with best practice or applicable laws.

We will update you about any new purposes of processing of your personal data from time to time, and we will obtain your prior consent for such new purposes where we are required to do so at law.

6. Sharing your information

We will share your information where it is lawful, necessary and proportionate to do so with (i) our third party service providers or sub-processors who may process personal data on our behalf, as part of the provision of our services to you (ii) our marketing and analytics partners deploying cookies and similar technologies in our services and otherpartners, as explained above, (iii) our affiliated companies for the purposes set out above, (iv) persons or authorities where we are compelled by law or responsible practices, (v) to the relevant entity in case of a merger, acquisition or collaboration, and (vi) other third parties where you have provided your consent.

7. Third parties may process your information

Our services may contain links to other websites, third party services or other online content, such as video platform plugins. You should check the privacy statements of these third party providers before you use them as we are not responsible for how they may process your personal data.

8. How long is your information kept?

We will only retain your personal information for as long as is necessary to fulfil  the purposes we collected it for, including without limitation for the purposes of satisfying any legal, accounting or reporting requirements.
The length of time we retain your personal data will depend on what it is being used for, generally, we will keep your personal information for the duration of our business trading relationship, unless you un-subscribe or contact us to ask to be removed from our data base. However, in practice the retention period will likely be shorter if the information is no longer needed or longer if required for lawful purposes.
Where it is no longer necessary to process your personal data, we will delete it or anonymise it by removing all details that may identify you, in accordance with applicable data protection legislation. For example, if you withdraw your consent to process your personal data, we will delete it unless it is required to be retained under applicable laws. You must back up your data if you wish to keep it for longer.

9. How do we secure your information?

We maintain appropriate organisational and technological safeguards to help protect against unauthorised use, access to or accidental loss, alteration or destruction of the personal data we hold. We also seek to ensure our third-party service providers do the same.
We will endeavour to use the least amount of personal data as is required for each purpose. We will employ pseudonymisation and anonymisation techniques, where appropriate.
Our staff will access your personal data on a “need to know” basis and all receive suitable levels of training regarding data security best practices.
We have in place processes to deal with any suspected data breach and will notify you and any regulator of a breach where we are required to do so under applicable laws.

10. Where is your information processed?

Generally, your information is held in the United Kingdom and the EEA. We may transfer your personal data to our affiliated companies, suppliers, sup-processors and other third parties in countries different to your country of residence, which may be outside the United Kingdom and the EEA, subject to our compliance with applicable rules about international transfer of personal data, which may change from time-to-time.

11. Opt-out

If you would like us to stop sending you marketing communications or to stop processing your personal data for direct or targeted marketing purposes, please let us know by emailing an Opt-out request message to dataprivacy@base-mc.com.
Alternatively, you can request to stop receiving our marketing communications at any time by clicking on the unsubscribe link at the bottom of each such marketing message.

12. Updates

If we make any changes to this notice you will be able to see them on this page. You should regularly check for updates, as indicated by the “Last updated” date at the top.  This page will be dynamically updated by base® as required over time. If you do not agree with the changes, please do not continue to use our website or services. Of course, if any such changes significantly affect you, we will ask for your prior consent where we are required to do so by law.  If you prefer to be removed from our contacts data base, please use the process outlined in 11. Opt-out section above.

13. Your data privacy rights

This section provides further disclosures and describes the rights in relation to your personal data that you may have under the General Data Protection Regulation (“GDPR”) or other relevant data protection laws.
A. Personal Data “Personal data” means any information relating to an identified or identifiable natural person; such person is known as a ‘data subject’.
‍B. Data subject rights Subject to certain exemptions, limitations and appropriate proof of identity, as a data subject, you will generally have numerous rights in relation to your personal data that you may exercise with the controller, including the following:

  • Right to information  about matters set out in this Privacy Notice. You may also contact us for further details about our retention policy and international data transfers using the contact details at the end of this notice.
  • Right to make an access request  to receive copies of personal data.
  • Right to rectification  of any inaccurate or incomplete personal data.
  • Right to withdraw consent  previously provided.
  • Right to object to  our processing of personal data based on our legitimate interests, and any automated processing and profiling.
  • Right to erasure  of personal data, within limited circumstances.
  • Restriction  on the processing of personal data.
  • Right to data portability  from one service provider to another, where applicable.
  • Right to lodge a complaint  with your country’s supervisory authority, such as the Information Commissioner’s Office in the UK.

If you wish to exercise your data privacy rights, you can contact us in writing by using the contact details at the end of this notice. All requests will be processed in a timely manner, generally within one month. If we cannot process your request within this period, we shall explain why and process it as soon as possible thereafter.

14. Contact us

Please contact us at dataprivacy@base-mc.com or via our website contact page if you have any queries or concerns about how we use your personal data. We will try to resolve your query without undue delay.