Inflecto reserve the right to change this policy at any time by updating this page. We recommend checking this page from time-to-time to keep up to date.
Who we are
Inflecto Media is a multi-award winning agency, providing lead generation services to our advertiser clients.
We are Inflecto Media Limited, a company registered in England with company number 06981563 and registered office at 7th Floor, Dashwood House, 69 Old Broad Street, London EC2M 1QS, UK.
If you have any questions in relation to this policy or our data processing, please contact us at:
Inflecto Media Limited
4 Percy Street
London W1T 1DF
Our Data Processing
Inflecto Media processes data for the following purposes:
(a) To provide services to clients: in order to provide our lead generation and communications related services, create reports, and improve our services, we may handle personal data of our clients’ current or potential customers (e.g. in order to manage an email or web or mobile marketing campaign). Clients may provide this data to us or we may obtain it in the course of providing the services. The data we process on behalf of our clients may include: email addresses (including “do not contact” lists), IP addresses, mobile device IDs, time and date, location, anonymous user IDs allocated to events by our platforms, operating system and browser details, referring site, and/or other contact details that you provide such as your name and address when responding to an offer or advertisement that they have engaged us to manage.
This may also involve retargeting technology to serve relevant and useful advertising to you on websites or apps. This is usually done via cookie data which is stored on your browser when you visit one of our partner's websites. This cookie data tells us more about your interests and browsing activity so in turn we can serve advertisements far more relevant to you. Cookies also enable us to manage campaigns (e.g. by detecting and combatting fraud, verifying what ads have been seen or clicked on, capping the number of times ads are seen, analysing trends and browsing behaviour, and testing).
We do this as a data processor, on the instructions of our clients, who are the “controllers” of this data. We keep this data secure in accordance with their instructions and this policy. Our legal basis is that this is necessary in order to perform our contracts with our clients. In addition our clients and partners must have: (i) your consent to setting cookies on your device; and (ii) your consent or other valid legal basis in accordance with the law for processing the relevant data. Normally you should contact the relevant client or partner site and review their privacy information in order to understand how they use your data. If you ask us about exercising your legal rights referred to in Section 7 below, then we may need to pass your request onto the relevant partner or client as we may not be in a position to take all the required action ourselves.
(b) To manage our relationship with you as a current client or supplier including invoicing for our services or paying your invoices: the legal basis for this is that this is necessary for the performance of the contract between our organisations.
(c) To manage our relationship with you as a potential client or supplier: the legal basis for this is that this is necessary for our legitimate business interests, i.e. developing our business, investigating new opportunities, or ensuring that we obtain suitable and cost-effective products and services. Please note that if you are an employee or consultant working with us then different data processing rules may apply – please contact your manager or usual contact at Inflecto Media.
(d) To provide content or information, which may include newsletters or marketing content: the legal basis for this is that this is necessary for our legitimate interests, i.e. managing and growing our business.
(e) To respond to any inquiry you have made (e.g. as a potential client, candidate, or other web user interested in our business): the legal basis for this processing is consent – you have freely and voluntarily provided your data to us and we will use it for the purpose it was provided.
We do not provide your data to third parties, except:
(a) where we use a data processor to carry out certain processing activities on our behalf (e.g. a subscriptions manager for our or our clients’ mailing lists, a provider of IP address or mobile ID tracking services, a hosting provider who stores data for us, advertising platforms that serve ads or provide ad space for our campaigns, or our accounting, tax or legal advisers). We do this on the basis of written contracts that require them to keep your data secure;
(b) to our clients where they are the “data controller” and we are merely processing data on their behalf; or
(c) if required to do so by a regulator, court, police force, or by law.
Our data processors may be based in countries within the European Union and EEA or other places officially recognised by the European Commission as having similar data protection laws. If not, we provide data to them only on the basis of legal safeguards that require them to keep your data as secure as under EU laws. These may include standard European Commission contractual clauses or the EU-U.S. Privacy Shield, and you may contact us as indicated above for a copy of such safeguards.
Your data will be stored by Inflecto Media for as long as is reasonably necessary to carry out the purpose for which it was provided (e.g. for at least as long as you are a client or supplier, or your subscription to a newsletter is still in effect). Sometimes we may need to keep it longer in order to comply with applicable laws such as accounting or tax laws (usually 6 years), or where there is a possibility of a legal claim (usually 6 years). Where data is used for marketing or business development, we regularly review our databases to ensure that the data is still relevant. At the end of campaigns, our contracts with our clients require us to destroy or pass all relevant data back to them, normally within [xx].
Provision of Data
If you are a customer of potential customer of one of our clients, then you will need to provide data as requested in order to receive the offer or participate in the promotion that you sign up for. Requests for exercise of your rights referred to in Section 7 below should normally be addressed to the particular client or partner, although we will do our best to direct any request we receive.
If you make an enquiry, or are a current or potential client or supplier, then without using your data we may not be able to respond to you or manage our contract or business relationship with you. So we may need to keep your data for some time for restricted purposes even if you have asked us to delete or stop using it.
Your Other Legal Rights
Applicable laws give you various rights relating to your data. For example, you are entitled to ask:
(a) for access to a copy of any personal data that Inflecto Media holds about you;
(b) to have incorrect personal data about you corrected;
(c) for data about you to be deleted (the “right to be forgotten”), to have processing restricted, or to object to particular processing;
(d) to receive a copy of any data that you have provided to us, for provision to a new service provider (“data portability”).
Where Inflecto Media processes any data based on consent that you have given to us, then you are always allowed to withdraw that consent (although the processing that took place before withdrawal will still be legal).
If you receive any marketing information from Inflecto Media and wish not to receive such information in future please email us at email@example.com. You also have the opportunity to opt out of future communications whenever we send you any such material.
We always encourage you to contact us through the details in Section 1 above to address any issues or doubts you may have in relation to processing of your data or to exercise your legal rights. As needed, we will also pass those requests on to our partners or clients. If you believe that your rights have not been respected, then you also have a right to complain to the relevant Supervisory Authority or Data Protection Authority, which for the UK is the “Information Commissioner’s Office”, to ask them for a decision.
Last updated: 1 June 2018
© Inflecto Media Limited, 2018, all rights reserved.