PRIVACY POLICY

 
 

Privacy Policy

The following document sets forth the Privacy Policy for the use of websites and applications operated or hosted by e-Mersion Media (UK) Limited and/or e-Mersion Media (Aust) Pty Ltd to align with the European General Data Protection Regulation (Regulation (EU) 2016/679) (the “Data Protection Legislation“).

SECTION 1: INTRODUCTION

  • e-Mersion Media (UK) Limited and/or e-Mersion Media (Aust) Pty Ltd (“e-Mersion Media” or “we“) are committed to providing you with the best possible customer service experience whilst respecting the privacy of individuals.

    1. This Privacy Policy aims to clearly outline our policies and procedures for collecting, using, storing and disclosing personal information of individuals. All of the different forms of data, content, and information described in this Privacy Policy are collectively referred to as “personal information”.

    2. e-Mersion Media’s service offering (the “Service“) involves building and hosting interactive digital magazine applications (each, an “eMM Application”) for our corporate clients (each, a “Magazine Owner”) to be made available to individuals through their devices (which include any devices which can operate an eMM Application (each a “Device“)).

    3. This Privacy Policy explains what we do with your personal information when: 

      • you access an eMM Application (together, the “Application Users“); 

      • you visit our website (https://www.e-mersion.media) (the “Website“) while browsing the internet (together, the “Website Users“); and 

      • you provide us with your business contact details in the course of business dealings with us (together, “Business Contacts”). 

    4. If you are an Application User, our primary purpose for using your personal information is to provide you with access to an eMM Application on behalf the relevant Magazine Owner. When we use your personal information to allow you to access and use an eMM Application, we do so on the instructions of the Magazine Owner. This makes us a “data processor” for the purposes of the Data Protection Legislation. For information about how the relevant Magazine Owner (i.e. the “data controller”) will use your personal information, please see the privacy policy of the relevant Magazine Owner. However, there may be certain circumstances under which we use your personal information for purposes that are not on behalf of the Magazine Owner or in accordance with instructions of the Magazine Owner, for example, where we need to use it for our own purposes. Under these circumstances, we are a “data controller” for the purposes of the Data Protection Legislation. Please see section 4 (“How do we use your personal information?“) for more information. 

    5. If you are a Website User, we use your information for our own purposes. This makes us a “data controller” for the purposes of the Data Protection Legislation. Please see section 4 (“How do we use your personal information?”) for more information.

    6. If you are a Business Contact, we use your information for our own purposes. This makes us a “data controller” for the purposes of the Data Protection Legislation. Please see section 4 (“How do we use your personal information?“) for more information.

 

  • It is important to point out that we may amend this Privacy Policy from time to time. Changes to this Privacy Policy will come into effect immediately upon such changes being published. Please visit this page if you want to stay up to date, as we will post any changes here. You acknowledge that we may make changes to this Privacy Policy and it is your responsibility to check back to this page from time to time to review the Privacy Policy. 

 

SECTION 2: WHAT KIND OF PERSONAL INFORMATION DO WE COLLECT

Application Users: 

  • We need to use personal information about you in the course of providing the Service to the Magazine Owners, to provide you with access to an eMM Application and for ancillary purposes set out in this Privacy Policy. Depending on the relevant circumstances and requirements, we, or a third party acting on our behalf (e.g. Google Firebase), may collect some or all of the personal information listed below to help us with this:

    • Name;

    • Email address;

    • Other personal information required by the Magazine Owner to identify your eligibility to access an eMM Application; and

    • Other information that you choose to share with us (e.g. when you respond to a survey or enter a prize draw); and

    • Log data from your Device, its software, and your activity using an eMM Application including the Device’s Internet Protocol (“IP”) address, browser type, locale preferences, geo-location information, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information, and other interactions with an eMM Application.

Website Users:

  • We collect a limited amount of personal information from our Website Users which we use to help us to improve your experience when using the Website and to help us manage the services we provide. This includes log data such as your Device’s IP address, browser type, the web page visited before you came to our website, information you search for on our website, locale preferences, identification numbers associated with your Devices, your mobile carrier, date and time stamps associated with transactions, system configuration information and other interactions with the Website. If you contact us via the Website’s contact form, we will collect any information that you provide to us, for example your name and contact details. 

Business Contacts:

  • We may collect, or be provided with, a limited amount of personal information of Business Contacts. Depending on the relevant circumstances and business dealings, we may collect some or all of the personal information listed below to help us with this:

    • Name;

    • Job title; 

    • Business email address and other contact details; and

    • Any further personal information contained in correspondence and documents provided in the course of our business dealings.

SECTION 3: HOW DO WE COLLECT YOUR PERSONAL INFORMATION?

Application Users:

  • We collect your personal information in three primary ways: 

  1. Personal information that you provide to us;

  2. Personal information that we receive from the Magazine Owner; and/or

  3. Personal information that we collect automatically.  

Personal information you provide to us 

  • Where you provide personal information to us when you register to use an eMM Application or within the eMM Application (e.g. responding to surveys or entering prize draws).

Personal information we receive from the Magazine Owner

  • Where we receive personal information about you from the Magazine Owner to verify your eligibility to access an eMM Application.

Personal information that we collect automatically

  • When you use an eMM Application, where we, or a third party acting on our behalf (e.g. Google Analytics), automatically record personal information in the form of log data from your Device, its software, and your activity using an eMM Application; and/or

    1. Where we, or a third party acting on our behalf (e.g. Google Firebase), collect your personal information automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 (“Cookies“).

Website Users:

  • When you visit the Website there is certain personal information in the form of log data that we may automatically collect. You may also provide us with information to us via the Website’s contact form. 

  • We also collect some limited personal information automatically via cookies, in line with cookie settings in your browser. If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 (“Cookies“).

Business Contacts:

  • When we communicate during our day-to-day business dealings, we may collect, or be provided with, a limited amount of your personal information.

SECTION 4: HOW DO WE USE YOUR PERSONAL INFORMATION?

Application Users: 

  • Our primary purpose for using your personal information is to provide the Service to the Magazine Owners and to provide you with access to an eMM Application. When we, or a third party acting on our behalf (e.g. Google Firebase), use your personal information to allow you to access and use an eMM Application, we do so on the instructions of the Magazine Owner. This makes us a “data processor” for the purposes of the Data Protection Legislation (and any third party acting on our behalf, a “data sub-processor”). Activities that we may carry out on this basis include: 

    • Allowing you to access and use an eMM Application;

    • Providing you with assistance (including technical assistance) in relation to your use of an eMM Application;

    • Providing you with interactive advertisements and other advertising features (and sharing your interaction activity with such advertisements collected from cookies and other similar technology (in the form of statistics and analytics) with our advertising partners. For more details, please see section 6 (“Information and Sharing”). If you would like to find out more about cookies, including how we use them and what choices are available to you, please see section 11 (“Cookies”).

    • Allowing you to submit feedback (e.g. in response to a survey) and participate in promotions (e.g. entering into prize draws) run by Magazine Owners;

    • Personalising and optimising your experience of an eMM Application and providing you with software updates; and

    • Ensuring compliance with the terms of our agreement with the Magazine Owners.

  • However, there may be certain circumstances under which we use your personal information for purposes that are not on behalf of the Magazine Owner or in accordance with instructions of the Magazine Owner. Under these circumstances, we are a “data controller” for the purposes of the Data Protection Legislation. Activities that we may carry out on this basis include:

    • Making announcements to you regarding our products and service offerings (see section 5 (“Marketing“) below); 

    • Ensuring compliance with our own obligations under applicable law and regulations;

    • Using your personal information to help us to establish, exercise or defend legal claims; and

    • Analysing, aggregating and anonymising log data/user statistics with the aim of improving an eMM Application for all Application Users or other eMM Applications that we operate or host.

  • We may use your personal information for these purposes if we have a legal basis for doing so. If you would like to know more about what this means, please see section 12 (“Legal bases for processing your personal information“). If you are not happy about this, in certain circumstances you have the right to object and can find out more about how and when to do this in section 9 (“How can you access, amend or take back the personal information that we hold about you”). 

Website Users: 

  • We use your personal information to help us to improve your experience of using the Website, for example by analysing your activity on the Website. If you contact us via the Website’s contact form, we will use the personal information that you provide to us to respond to you. This makes us a “data controller” for the purposes of the Data Protection Legislation.

Business Contacts:

  • We use your personal information to communicate with you and carry out our day-to-day business dealings with you. 

SECTION 5: MARKETING

Application Users

  • We may wish to use your personal information in order to let you know about, and invite you to participate in, other products and service offerings in the following ways:

    • Providing you with marketing communications on behalf of Magazine Owners (which may be by email and/or through push notifications, for example, to notify you that new issues of digital magazines or new features for an eMM Application are released (where such notifications are switched on at your Device’s Operating Service level)); and

    • Providing you with cross-marketing communications about eMM Applications (relating to other magazine titles) and other e-Mersion Media services.

  • We need your consent for some aspects of these activities which are not covered by our legitimate interests (in particular, the delivery of direct marketing to you through digital channels) and, depending on the situation, we’ll ask for this via an opt-in.

  • If you want to know more about how we obtain consent, please see section 12 (“Legal bases for us processing your personal information“). If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so in section 9 (“How can you access, amend or take back the personal information that we hold about you?“) 

Business Contacts

  • We may wish to use your personal information in order to tell you about the Service and to help you host your digital magazines. We will generally do this by email however, we will not, as a matter of course, seek your consent when sending marketing materials to a business/corporate email address. If you are not happy about this, you have the right to opt out of receiving marketing materials from us and can find out more about how to do so in section 9 (“How can you access, amend or take back the personal information that we hold about you?“). 

  • If you want to know more about how we obtain consent, please see section 12 (“Legal bases for us processing your personal information“). If you are not happy about our approach to marketing, you have the right to withdraw your consent at any time and can find out more about how to do so in section 9 (“How can you access, amend or take back the personal information that we hold about you?“).

SECTION 6: INFORMATION SHARING AND DISCLOSURE

  • Where appropriate and in accordance with applicable laws and requirements (and where we use your personal information as a data processor on behalf of and under the instructions of a Magazine Owner in accordance with our obligations under our agreement with a Magazine Owner), we may share your personal information in the following ways: 

    • Magazine Owner: We may provide your personal information to the relevant Magazine Owner in order to enable us to ascertain whether you are eligible to access an eMM Application (for example, to confirm that your personal information match against its customer relationship management system), allow you to submit feedback (e.g. in response to a survey) or participate in promotions (e.g. entering into prize draws). We may also provide to the Magazine Owner statistical data about your use of an eMM Application, which may include information about your activity using an eMM Application or other interaction data. It will not include information that could personally identify you. 

    • Service Providers, Business Partners and third parties: We may use certain trusted third party companies and individuals to help us provide, analyse, and improve eMM Applications (including but not limited to data storage, maintenance services, database management, web analytics, and improving the features of eMM Applications). These third parties may have access to your personal information only for the purposes of performing these tasks on our behalf and under obligations similar to those in this Privacy Policy.

    • Other Service Providers, Business Partners and third parties: We may share your personal information with our agents or third party service providers (including professional advisers and telecommunication service providers) which require your personal information to provide their services to e-Mersion Media. Such agents and third party service providers will not be permitted to use your personal information for any other purpose.

    • Advertising Partners: We may provide your statistical information such as reach, unique impressions, and anonymized user data, with our advertising partners where you interact with their advertisements contained in an eMM Application. This information will not include information that could personally identify you.

    • Compliance with Laws and Law Enforcement Requests: We may disclose to parties outside e-Mersion Media, personal information about you that we collect when we have a good faith belief that disclosure is reasonably necessary to (a) comply with a law, regulation or compulsory legal request; or (b) to protect e-Mersion Media’s [or a Magazine Owner’s] intellectual property rights. If we provide your personal information to a law enforcement agency as set forth above, we will remove our encryption from the personal information before providing them to law enforcement agencies.

    • Business Transfers: If we are involved in a merger, acquisition, or sale of all or a portion of our assets, your personal information may be transferred as part of that transaction. 

    • Non-private or Non-Personal Information: We may disclose your non-private, aggregated, or otherwise non-personal information, such as usage statistics of an eMM Application.

    • Group Companies: We may share your personal information with our group companies. 

SECTION 7: HOW DO WE SAFEGUARD YOUR PERSONAL INFORMATION? 

  • We are committed to taking all reasonable and appropriate steps to protect the personal information that we hold from misuse, loss, destruction or unauthorised access. We do this by:

    • using technical and administrative safeguards to protect personal information. We also use system security and data encryption to protect personal information, although we cannot guarantee that our safeguards will always be successful; 

    • having in place policies to, for example, deal with any suspected data breaches; and 

    • choosing cloud service providers with appropriate technical and organisational measures and storing all personal information with these service providers (rather than storing any personal information within our own servers or at any of our premises. 

  • While we use commercially reasonable security measures to prevent unauthorised persons from accessing our files or tampering with the Website and eMM Applications, we cannot guarantee that these efforts will always be successful as no data transmission over the internet or storage of information can be guaranteed to be completely secure. Personal information may be accessed and viewed by other internet users, without your knowledge and permission, while in transit to or from us, and you transmit such at your own risk

SECTION 8: HOW LONG DO WE KEEP YOUR PERSONAL INFORMATION FOR?

  • We will not keep your personal information for longer than we are permitted to do so under our agreement with the Magazine Owners or as is necessary for the purposes for which we have collected it unless we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements.

  • When we are no longer permitted under our agreement with the Magazine Owners or it is otherwise no longer necessary to retain your personal information, we will delete the personal information that we hold about you. While we will endeavour to permanently erase your personal information once it reaches the end of its retention period, some of your personal information may still exist, for example if it is contained with back-up systems. For our purposes, this data has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again.

SECTION 9: HOW CAN YOU ACCESS, AMEND OR TAKE BACK THE PERSONAL INFORMATION THAT WE HOLD ABOUT YOU? 

  • You have various rights in relation to the personal information that we hold about you.

  • To get in touch about these rights, please contact us at privacy@e-mersion.media or the relevant Magazine Owner. 

  • If you are an Application User and you wish to make a request in relation to our use of your personal information for the purposes of providing the Service to a relevant Magazine Owner (and in respect of which we are a data processor), please contact the relevant Magazine Owner in the first instance to handle your request. If you contact us, we will refer your request to the relevant Magazine Owner. 

  • If you are an Application User and you wish to make a request in relation to our use of your personal information which is unconnected to a Magazine Owner or you are a Website User or Business Contact, please contact us and we will handle your request. 

  • The Data Protection Legislation gives you the following rights in relation to your personal information:

    • Right to object: This right enables you to object to us processing your personal information. 

    • Right to withdraw consent: Where we have obtained your consent to process your personal information for certain activities, you may withdraw this consent at any time and we will cease to carry out that particular activity that you previously consented to unless we consider that there is an alternative legal basis to justify our continued processing of your personal information for this purpose, in which case we will inform you of this condition. 

    • Data Subject Access Requests (DSAR): You may ask us to confirm what information we hold about you at any time, and request us to modify, update or delete such information. You may also request a copy of the information we hold about you. 

    • Right to erasure: You have the right to request that we “erase” your personal information in certain circumstances. We will try to delete your personal information quickly upon request and if desired make it available to you. While we will endeavour to permanently erase or return your personal information upon request, some of your personal information may still exist within our systems, for example if it is waiting to be overwritten. For our purposes, this personal information has been put beyond use, meaning that, while it still exists in the electronic ether, our employees will not have any access to it or use it again. We may retain and use your personal information if we believe that the law or other regulation requires us to preserve it (for example, because of a request by a tax authority or in connection with any anticipated litigation) or if we require it to enforce our agreements. 

    • Right to restrict processing: You have the right to request that we restrict our processing of your personal information in certain circumstances, for example if you dispute the accuracy of the personal information that we hold about you or you object to our processing of your personal information for our legitimate interests. If we have shared your personal information with third parties, we will notify them about the restricted processing unless this is impossible or involves disproportionate effort. We will, of course, notify you before lifting any restriction on processing your personal information.

    • Right to rectification: You also have the right to request that we rectify any inaccurate or incomplete personal information that we hold about you, including by means of providing a supplementary statement. If we have shared this personal information with third parties, we will notify them about the rectification unless this is impossible or involves disproportionate effort. You may also request details of the third parties that we have disclosed the inaccurate or incomplete personal information to. Where we think that it is reasonable for us not to comply with your request, we will explain our reasons for this decision.

    • Right of data portability: If you wish, you have the right to request that we transfer your personal information to another third party. To allow you to do so, we will provide you with your personal information in a commonly used machine-readable format so that you can transfer the data. Alternatively, we may directly transfer the personal information for you. This right of data portability only applies to certain types of personal information. 

    • Right to lodge a complaint with a supervisory authority: You also have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction. In the UK the data protection authority is the Information Commissioner’s Office (www.ico.co.uk). If you are in the European Union, contact details for the data protection authority in your country can be found here

SECTION 10: HOW DO WE STORE AND TRANSFER YOUR PERSONAL INFORMATION INTERNATIONALLY? 

  • In order for us to carry out the functions described in this Privacy Policy (for more details, please see section 4 (“How do we use your personal information?”) your personal information may be processed by us (or our third party service providers) outside of the European Economic Area (EEA)/UK and the territories where the entities set out in section 6 (“Information Sharing and Disclosure“) are located include Australia.

  • We want to make sure that your personal information is stored and transferred in a way which is secure. If you are based within the EU/UK we will only process and/or transfer data outside of the European Economic Area or EEA (i.e. the Member States of the European Union, together with Norway, Iceland and Liechtenstein)/UK where it is compliant with Data Protection Legislation and the means of transfer provides adequate safeguards in relation to your personal information, including for example:  

    • By way of a data transfer agreement with the relevant Magazine Owner, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal information by controllers in the EEA/UK to controllers and processors in jurisdictions without adequate data protection laws; or 

    • By way of a data transfer agreement with a third party, incorporating the current standard contractual clauses adopted by the European Commission for the transfer of personal information by controllers in the EEA/UK to controllers and processors in jurisdictions without adequate data protection laws; or 

    • By transferring your personal information to an entity which has signed up to the EU-U.S. Privacy Shield Framework for the transfer of personal information from entities in the EU to entities in the United States of America or any equivalent agreement in respect of other jurisdictions; or 

    • By transferring your personal information to a country where there has been a finding of adequacy by the European Commission in respect of that country’s levels of data protection via its legislation; or 

    • Where it is necessary for the conclusion or performance of a contract between us and a third party and the transfer is in your interests for the purposes of that contract; or

    • Where you have consented to the data transfer.

SECTION 11: COOKIES 

Application Users

  • We, as well as certain third parties that provide content and other functionality on an eMM Application, use cookies, web beacons, pixels, and other similar tracking technologies in the process of providing you with access to an eMM Application, which may lead to us collecting personal information.

  • Cookies are text files saved to the Device you use to access an eMM Application. By storing such information, cookies can, among other things, remember your preferences and settings for an eMM Application and helps us to analyse how you use an eMM Application.

  • A pixel tag, also known as a web beacon or clear GIF, generates a notice of the visit and permits the website to save or read cookies. We may use these to count the number of users who have visited a particular page, to deliver or communicate with cookies, and to understand usage patterns.

  • We use these technologies to:

    • Enable certain functionalities, as well as to analyse and improve your use of an eMM Application.

    • Store your sign-in credentials and preferences so that you don’t have to enter those credentials and preferences every time you log on to an eMM Application.

    • Help us and third parties to provide you with relevant content by collecting information about your use of an eMM Application. 

  • You can either keep or delete cookies according to your preference, or clear all cookies stored on your Device. 

  • Cookies are an important part of an eMM Application, so you should be aware that if you choose to remove cookies, this could affect the availability and functionality of an eMM Application.

Website Users

  • We may use “cookies” or other tracking technologies (e.g. web beacons, single-pixel, or clear GIFs) to track how you use the Website for analytics and security purposes. A cookie is a file stored on your computer or other device used to access the Website to uniquely identify your computer or device or to store information or settings on your computer or device. A pixel tag, also known as a web beacon or clear GIF, generates a notice of the visit and permits the Website to save or read cookies.

  • We use these technologies to enable certain functionalities, as well as to analyse and improve your use of the Website, and help us and third parties provide you with relevant content by collecting information about your use of the Website.

  • The cookies that we use fall into the following categories: 

    • Strictly Necessary Cookies: These cookies are essential for the running of the Website. They allow you to easily access and navigate through the Website and use the relevant features. 

    • Functionality Cookies: These cookies can be very useful to you and help to deliver a more personalised experience They are used to remember your preferences and choices, such as changes you’ve made to text size or fonts, your username and password so that these preferences can be remembered. 

    • Performance Cookies: These cookies collect information about how visitors use the Website, for example, which pages visitors visit most often, and help us to make improvements to the Website. Performance cookies do not collect information that identifies a visitor, all information collected is aggregated and anonymous. 

    • Targeting / Advertising Cookies: We use these cookies to deliver marketing that is relevant to you based on your preferences and browser history which may be displayed on the Website or others’ websites. We may also use these cookies to analyse how successful our marketing has been by using data analytics to track user clicks and engagement with the content produced.

  • All cookies listed above can also be first or third party cookies and persistent or session cookies:

    • First or Third Party Cookies – first party cookies are set and collected by us whilst third party cookies are set and collected by external companies who help us deliver our services. For instance, cookies set and collected by companies assisting us with data analytics, in order to improve users experience and functionality of the Website.

    • Persistent or Session Cookies – persistent cookies are set up with an explicit expiry date so that they will live on your computer or device for a set amount of time before being deleted. Session cookies on the other hand are only stored temporarily during a browsing session and are deleted from your computer or device when you close the browser.

  • When you first visit the Website, you will be presented with a pop-up screen informing you of our use of cookies and asking you to provide your consent for such use. The pop-up screen may not reappear for all your subsequent visits to the Website, but you may adjust your web browser software if you do not wish to receive cookies or web beacons, but this may prevent you from taking advantage of some of the Website’s features. Please refer to your browser instructions or help pages to learn more about these functions.

  • Some web browsers may transmit “do-no-track” signals to websites with which the browser communicates. The Website does not currently respond to these “do-not-track” signals.

  • The following cookies may be used:

    Cookie Name

    What do we use this cookie for?

    Duration

    Necessity/Opt-out method

    _ga

    Used by Google Analytics to distinguish users.

    2 years

    Opt-out by turning off tracking cookies during initial page load pop up.

    _gid

    Used by Google Analytics to distinguish users.

    24 hours

    Opt-out by turning off tracking cookies during initial page load pop up.

SECTION 12: LEGAL BASES FOR US PROCESSING YOUR PERSONAL INFORMATION

Where we process your personal information as a data processor on behalf of and under the instructions of a Magazine Owner, the Magazine Owner is responsible for ensuring that there is a legal basis for us processing your personal information on its behalf. 

  • Where we process your personal information as a data controller, we need to ensure that there is a legal basis to justify our processing of your personal information. There are a number of different ways that we are lawfully able to process your personal information. We have set these out below.

    • Where processing your personal information is necessary for us to carry out our obligations arising from any contracts entered into between you and us

  • We process certain personal information where it: “is necessary for the performance of a contract to which [you] are a party.”

  • If you enter into a contract with us in relation to any service offerings outside of an eMM Application, we may process certain personal information about you in order to perform our obligations under this contract.

  • Where processing your personal information is within our legitimate interests

    • We can process certain personal information where it “is necessary for the purposes of the legitimate interests pursued by [us] or by a third party, except where such interests are overridden by the interests or fundamental rights or freedoms of [you] which require protection of personal information.”

      1. The ways in which we may process your personal information for the purposes of our legitimate interests include: 

        • enforcing the terms of the Website and eMM Applications;

        • analysing, aggregating and anonymising log data/user statistics to improve the Website for all Website Users and the eMM Applications for all Application Users;

        • communicating with you about your access to the Website and eMM Applications;

        • responding to your questions, feedback, claims or disputes;

        • improving the Service, Website, eMM Applications and other products and services offered by us, and ensuring that the Service, Website and all eMM Applications run smoothly; and

        • ensuring the Service, Website, eMM Applications, systems and information are secure.

  • Where you give us your consent to process your personal information

    • In certain circumstances, we will seek to obtain your opt-in consent before we undertake certain processing activities with your personal information. In plain language, this means that: 

      • You have to give us your consent freely, without us putting you under any type of pressure; 

      • You have to know what you are consenting to – so we’ll make sure we give you enough information;

      • You should only be asked to consent to one processing activity at a time – we therefore avoid “bundling” consents together so that you don’t know exactly what you’re agreeing to; 

      • You need to take positive and affirmative action in giving us your consent – we’re likely to provide a tick box for you to check so that this requirement is met in a clear and unambiguous fashion; and

      1. We will obtain your opt-in consent prior to sharing your personal information with third party applications and carrying out certain marketing activities.

      2. As and when we introduce these particular processing activities, we will provide you with more information so that you can decide whether you want to opt-in.

      3. You have the right to withdraw your consent to these activities. You can do so at any time, and details of how to do so can be found above at section 9 (“How can you access, amend or take back the personal information that we hold about you”).

  • Where processing your personal information is necessary for our compliance with a legal obligation

    • In certain circumstances, we may disclose your personal information for the purposes of compliance with a legal obligation (for example, to comply with a law, regulation or compulsory legal request).

      1. We do not think that any of the above activities prejudice you in any way. However, you do have the right to object to us processing your personal information in certain circumstances. If you would like to know more about these circumstances and how to object to our processing activities, please see section 9 (“How can you access, amend or take back the personal information that we hold about you”).

SECTION 13: WHO IS RESPONSIBLE FOR PROCESSING YOUR PERSONAL INFORMATION AND CONTACT INFORMATION 

  • If you would like further information about how we handle your personal information, if you have any concerns regarding this Privacy Policy or if you wish to exercise your legal rights, please contact privacy@e-mersion.media. Please outline to us your concerns and am e-Mersion Media representative will be in touch to discuss the matter. 

  • The companies responsible for compliance with this Privacy Policy are:

    • e-Mersion Media (UK) Limited (company number 11857059) of 3rd Floor 12 Gough Square, London, England, EC4A 3DW; and

    • e-Mersion Media (Aust) Pty Ltd (ACN 605 098 539) of Level 19, 2 Southbank Blvd., Southbank, Victoria, 3006, Australia and our EU Representative is e-Mersion Media (UK) Limited (company number 11857059) of 3rd Floor 12 Gough Square, London, England, EC4A 3DW, SL1 1PG.