Last Updated: September 1, 2018
Navona Media and Data Collection Practices
Navona Media is engaged in the field of digital marketing. We are registered as a data controller with ICO number ZA354058. We have implemented best practices and we actively follow all applicable laws governing the acquisition, compilation, storage and distribution of consumer data. Specifically, Navona Media specializes in email and SMS marketing promotions.
Information Collection and Use of Information
When you complete an enquiry form on one of our sites or one of our partners’ sites, we collect the personal data you entered there and this information may include your name, email address, physical address, telephone number, gender and age. By using cookies, we also collect website usage information.
We or one of our data partners may provide our personalized services to you by using your telephone or email information, this may include information about offers, products and services. Your contact information is used to contact you when necessary. If you do not want to be contacted, please let us know by sending us an email message at email@example.com
Listed are some examples of how we use your details: a) to provide you with the information on services and products that you requested from us; b) to execute our obligations arising from any agreements entered into between you and us; c) to let you know about any changes to our service; d) update selected partners database records for the prevention of fraud, debt tracing and anti-money laundering purposes; e) send you offers that might be of interest to you.
We may send you the information about products, services, offers, competitions and other news where we feel these may interest you. This may include details on services/products such as loans, finance, insurance, travel and sweepstakes. Depending on the type of contact details you have given to us, we may contact you by phone, email or SMS. This will be done only if/where you have consented to receiving such promotional messages from us.
Processing your information: Why and how
All the data we process is for the sole purpose of digital advertising. We process your details to share with Third Party Data Controllers to send you information about Services and Products that may be of interest to you.
We use your data a) to match your interests in services and products which are offered by Sponsors or other third-party organizations; b) for customer services, such as answering requests; c) if needed for the conclusion of a contract with the data controller; d) for legal obligation.
Withdrawing your consent – how to unsubscribe
You can withdraw consent any time. Simply, send us an email firstname.lastname@example.org with your request to be removed from our database. Please include your First Name, Last Name, Mobile number or Email Address and Postal Code. We can then quickly identify you and remove your personal details from the database.
Please note, that it can take up to 28 days to remove your details from all Third-Party Controllers. Alternatively, you can call us on +1 206 973 7389
Please be aware that a Subject Access Request can only be accepted in writing. In this context, the fastest way to make a request is by email. We cannot give out personal details over the telephone without first taking the required and necessary steps to satisfy our obligations to the ICO, GDPR and the Data Protection Act.
You may withdraw your consent at any time.
What information is collected
When you register your personal details on site with our Data Contributors, you may provide any of the data fields listed below. We aggregate this data and process it by combining information to create a Single Customer View.
Date of Birth
Time & Capture Date
In addition to the Data Fields that you entered during an application, we may also combine data that can be found in the publicly available databases at an Individual level, relating to you or your household.
We are working closely with other companies (including, for example, business partners, technical sub-contractors, payment processors, delivery companies, advertising/marketing networks, analytics providers, search information providers, credit reference agencies) and may receive data about you from them.
Below are listed categories of personal and consent data which are collected to provide the services are:
• the user’s full name, title, gender, date of birth, telephone number, email address, IP address, full postal address and other similar data that’s required to communicate with the person who filled out the form
• preferences on how the user wishes to be contacted: via email, mobile phone number and sms or mms.
• opt-out request when user wishes not to be contacted for marketing purposes at all.
• user’s preferences for types of promotions, goods or services.
• For sweepstakes, prize winner details are collected, including photograph of the prize winner when disclosed.
• further data/information requests and/or contact history.
We may share your details with selected third parties that are offering services or products that we believe will be of interest to you. These companies are operating in the following sectors:
Retail: Leisure & Fashion Products, Drink & Food Producers & Retailers, Advertising & Marketing, General Retailers
Financial Services: Comparison Websites, Debt Collection, Financial Services/Providers, Insurance Providers, Payday & Loan Providers/Services, Shares
Lifestyle: Astrology, Automotive, Competition Sites, Sweepstakes, Education, Research, Self Improvement, Gambling, Health, Welfare, Parenting, Subscription Services, Leisure & Travel Pursuits, Tracing, ID and Fraud
Household & Technology: Electric, Gas, Water & Multi-Utilities, Home Improvement, Home Construction, Household Services & Goods, IT Software & Services, Media, TV, Radio, Film, Online & Print, Real Estate, Telecommunications
Public Sector: Government, Political, Legal Services, Not-for-Profit, Tracing Activities, Personal Injury
Claims management companies: Personal Injury Claims, Mis-sold PPI, Mis-sold Mortgages, Mis-sold Investments, SERPS/Mis-sold pensions, Ascend
They may contact you by email, mail, phone, through on-line advertising or social media. Your mobile telephone number for SMS purposes will be shared only if you have agreed to organisations or sectors contacting you.
We may also share your details with selected third parties for the purposes of Market research and analysis, aggregation, monetization, profiling, credit and risk management, revenue collation, database verification and/or to update their records for fraud prevention, debt tracing and anti-money laundering purposes, segmentation and suppression.
Sharing your information with third parties
We may share your information with any of the Third-Party Controllers or Sub Processors listed below:
Company Name: Worldwide Clicks
Address: 210 – 128 W Hastings St, Vancouver, BC, V6B 1G8, Canada
Company Name: Inbox T Group
Address: 938 Howe St, Vancouver, BC, V6Z 1N9, Canada
Your information might be shared with selected third parties including:
• Suppliers, business partners and sub-contractors for the performance of any contract we enter into with them or you.
• Search engine and analytics providers that assist us in the optimisation and improvement of our sites.
Your personal information might be disclosed to third parties:
• If we sell our company in which case the personal data that we hold will be part of the transferred assets.
Notwithstanding other provisions, we may also engage a third-party partner to help us identify users and deliver to them advertisements and content that’s based on user’s interests. Information such as your name, postal address, email, or other identifier may be shared with our partners. It may be shared in non-human readable form to make sure your information is secured. Other information might be collected from our partners directly from your device, such as your IP address, device ID, details about your operating system or browser, and depending on your device settings, your geographic location data, including GPS coordinates (e.g. latitude and/or longitude) or similar data regarding the location of your mobile device; may combine our personal and non-personal information about you with data from other sources; and a unique cookie might be placed or recognized on your browser.
Your information will only be shared if you have given explicit consent. This means that you have made a positive action to opt-in and agree to Third Party Controllers to contact you directly or then to pass on your information to a Sub Processor to get in touch with you. A Sub Processor for example may be a Call Centre who are employed by a Utility or Telecom company to tell you about Services and Products that may be of benefit to you.
When you make a registration or have entered your information on a Data Contributor’s website or app the options were presented to you and you were asked to agree to third party marketing by the channel/s that you specified. In most cases, you will be able to choose from four options which are SMS (Text Message), Email, Telephone or Post.
Depending on your preferences, you can select one or all options. The ability to process your loan application, enter a competition draw or subscribe to a newsletter is not affected if you choose to decline and opt-out of sharing your details with Third Party Controllers.
Accessing your information. Subject access requests.
You have the right to see what personal information we have on you. To get a copy of the personal data we have on you, you must submit a Subject Access Request (SAR). A SAR must be made in writing in the form of a written letter or an email.
In order to do provide you with your personal information that we have on record, i.e. to process your request, we have to follow an identification process and be competly sure that you are the person whom the data relates to. Unless you have the required written authority or demonstrable Power of Attorney, you cannot make a SAR on behalf of another person.
The easiest way to make a SAR is to send us an email at email@example.com
You must include the following information with any SAR – full name, full address and the channel from which you have received marketing communication e.g. Email Address, Telephone Number or Postal Address
In order to verify your address, we also need to receive a copy of your recent utility bill (or similar) that has your address.
A fee might be charged depending on your request and that fee can be up to £10.00 per request.
After we receive the information outlined above, we will contact you directly to process your SAR.
For more details and tips on what you are entitled to, please read the information from the UK Supervisory Authority here http://ico.org.uk/for-the-public/personal-information/
Changing your information
At any time, you have the right to request that we change, update or amend the information that we hold about you. You also have the right to withdraw from any offer, competition or service. You can also ask us not to contact you with any further competitions, offers or services.
If you would like to request that we change your information that we have on file, please send us an email message at firstname.lastname@example.org
The personal information of the users is only supplied to those companies who are necessarily involved, including third parties, the data management organizations or application management or other companies in charge of the database performance or to those entities that we have a legal obligation.
Navona Media respects the security and confidentiality of the data you entrust to it. We implement appropriate organizational and technical measures, on a continuous basis, to secure the personal information and to make sure there is a sufficient level of protection as pertaining to the Regulation of Personal Data.
The security of your personal data is important to us. Keep in mind that no method of data transmission over the internet, or method of electronic storage is completely secured. Navona Media will take appropriate organizational and technical measures to protect your personal information. Access to your personal data is restricted to prevent unauthorized access, modification and is only allowed to our employees on a need-to-know basis.
We are fully aware how important is to safeguarding the information that is under our control. We always aim to take all reasonable steps to protect it. All data that is collected from our data providers and contributors is stored on secure servers. We have rigorous confidentiality and security procedures covering the storage and disclosure of such information in accordance with the Data Protection Act 1998.
However, transacting and providing information over the internet has inherent security risks. Navona Media cannot be held accountable or responsible for any security breach that is outside our reasonable control or not due to our negligence or willful default.