1.1. BASE Media Cloud Limited (“base”) is the personal data controller for the processing of personal data in connection with the use of base’s cloud-based services (the “Platform”).
1.2. Personal data is all and any kind of data that, directly or indirectly, can be used to identify or contact a natural person.
1.3. You will be asked to provide personal information in order to set up a user account to use the Platform and any services connected to it. The collected personal data will include user’s full name and e-mail address, as well as information regarding the use of the Platform. If you choose to provide such information, base may also process data concerning chosen alias and phone number.
1.4. If you choose to purchase services through invoice, base will, in addition to the information prescribed in 1.3 above, need an address to which invoices should be sent, as well as other (company) billing information, being name of contact person and company VAT- number.
1.5. base may also have received your personal information from a third party, through user directory services. In such cases, base will notify you of the processing of your personal data within four weeks from the commencement of processing.
1.6. base uses the personal data to manage the user account as well as to communicate with users and to send relevant notices. The personal data is therefore necessary in order for base to administrate the accounts and use of the granted license to use the Platform in accordance with the user terms.
1.7. If you give your consent, base may also collect and use personal data to operate and improve the Platform, base’s websites, services and products, and to make them easier to use. The personal data may also be used for research and data analysis for the same purpose.
1.8. Users may at any time request access to the processed personal information, as well as to request changes, corrections or deletion of any inaccurate data as well as request for a restriction of base’s processing of data. Users also have the right to object to base’s processing and has the right to data portability. Such requests shall be sent in writing to BASE Media Cloud (trading as base), 62 Michelham Gardens, Twickenham, TW1 4SB, or e-mail support@base-mc.com. In addition, users may at all times make changes to the processed personal information on the user account.
1.9. base is cautious of your privacy and integrity and makes its best efforts to safeguard your personal data. Should you nevertheless have remarks on the processing, you are most welcome to contact us on the abovementioned contact information. You are also always entitled to contact the supervisory authority.
1.10. base and its affiliates may share user’s personal information with each other and use it in consistency with this privacy policy. base may also share certain personal information to third party partners to provide or improve base’s products and services. However, base will not share personal information with third parties for their marketing purposes unless base has received explicit consent to such use.
1.11. If a user uploads images, video or other content that holds personal data, or adds metadata, either manually, using the available API’s, or in any other way possible, containing personal data on already existing media assets or content, said user is the personal data controller for such information and is thus fully responsible for the processing of such information and that the processing of the information is compliant with applicable laws, such as the General Data Protection Regulation ((EU) 2016/679) and UK GDPR. Said user will control the purpose for the processing of such personal data. base will be the personal data assistant for such processing and will not process the personal data for any other purpose than storage on behalf of the user.
1.12. Processing of personal data is described in more detail in the base Data Processing Agreement, as required by the General Data Protection Regulation ((EU) 2016/679) and UK GDPR.
2.1. base software suppliers may use technologies, such as cookies, to collect information about the page’s users ́ view, the links users ́ click and other actions users take on base’s third-party supplied software services. Cookies are small text files that are stored on the hard drive through web browsers.
2.2. base software suppliers may use cookies in order to store a user’s preferences and other information on the user’s computer in order to save time by eliminating the need to repeatedly enter the same information, for example by remembering personal information when using the Platform, and to display user’s personalised content and targeted advertising upon later visits to its websites. However, the cookies used on base third party supplier’s websites does not normally contain information that identifies users personally.
Cookies on base software supplier’s websites
2.3. base software suppliers may use session cookies as well as persistent cookies on their websites. A session cookie is a temporary cookie which is erased when a session is ended, i.e. usually when the browser is closed, while a persistent cookie is stored in one of the browser’s subfolders until deleted manually or the set duration period of the persistent cookie expires.
2.4. base software suppliers may use cookies such as ph_hasloggedin in order to determine whether to show “sign up” or “log in” when prompting a user to log in, ph_st_variants in order to determine which version of a page to show to a user, and ph_sessionid in order to remember information about a logged in user.
Third party cookies on base software supplier’s websites
2.5. base software suppliers may also use third party cookies. Third party cookies may be necessary in order for third parties to provide its services to base. Such third party cookies may include __ga in order to access e.g. Google Analytics data.
2.6. Users have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but this can be avoided through modifying the settings to decline cookies as well as delete existing cookies from the device. If users choose to decline and/or delete cookies, they may not be able to use all features of base software supplier’s websites or services that depend on use of cookies.
UPDATES
Our Privacy Policy may change from time to time and made available to the Customer. This text was last updated 12th January 2022.
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.
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:
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.
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.
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.
To assist and contact you in relation to your enquiry.
Contact details
Details of your enquiry
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.
To provide our services to you, such as our website, online content and other online services.
Device & browser data
Engagement information
Website usage data
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.
To provide our services to you, such as our website, online content and other online services.
Contact details
Opportunity records
Preferences and interests
Engagement information
Necessary for our legitimate interest in understanding and maintaining our business relationships and administering our business.
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.
Contact details
Preferences and interests
Engagement information
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.
To engage with you about surveys, focus groups and software assessment (beta) programmes.
Contact details
Preferences and interests
Engagement information
We will obtain your consent where required by law. Necessary for our legitimate interest in developing our business and organising related business activities.
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.
Contact details
Preferences and interests
Engagement information
Third party data
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.
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.
Contact details
Engagement information
Preferences and interests
Third party data
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.
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.
Aggregated data based on your participation information, engagement information, device & browser data, website usage data and preferences and interests.
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.
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.
All information as is necessary and proportionate for the administration of our business.
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.
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.
Contact details
including address and email address
payment information
Necessary for the performance of our contract with you, should you procure our services via an online payment mechanism.
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.
All information as is necessary and proportionate to enable the relevant service to be provided to you.
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.
To monitor our networks, website and systems for suspicious activities, test and audit our systems and deploy appropriate security measures.
Website usage data, device and browser data.
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.
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.
Contact details, browser and device data, website usage data, third party data.
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.
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).
Health information provided by you.
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.
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.
All information as is necessary and proportionate.
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.
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.
All information as is necessary and proportionate in connection with the event.
Necessary for our legitimate interest in acting in the best interest of our shareholders and investors and complying with our legal obligations.
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.
Any information subject to mandatory processing or disclosure, where this is necessary and proportionate
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.
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.
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.
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.
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.
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.
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.
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.
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:
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.
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.
