Privacy policy

Introduction

Welcome to Network N Media Limited's privacy policy. We are committed to safeguarding the privacy of our website visitors and service users. This privacy policy aims to give you information on how Network N Media Limited collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter or enter a competition.

Network N Media Limited is the controller and responsible for your personal data (collectively referred to as "Network N Media", "we", "us" or "our" in this privacy policy).This policy applies to all of the websites which we own or operate and where we are acting as the data controller; in other words, where we determine the purposes and means of the processing of that personal data.

Contact Us

If you have any questions about this privacy policy or our privacy practices, please contact our data manager in the following ways:

By post: Data Controller, Network N Media Ltd. Circus Mews House, 30 Circus Mews, Bath, England, BA1 2PW.

By email: [email protected].

You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

Changes to the privacy policy

We keep our privacy policy under regular review. This version was last updated August 14 2023.

You should check this page occasionally to ensure you are happy with any changes to this policy. We may notify you of changes to this policy by email or messaging system on our website where one exists.

Third-party links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

How we use your personal data

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

In this section we have set out:

(a) the general categories of personal data that we may process;

(b) in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;

(c) the purposes for which we may process personal data; and

(d) the legal basis of the processing. Note that we may process your personal data for more than one lawful basis depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal basis we are relying on to process your personal data where more than one ground has been set out below.

In addition to the specific purposes for which we may process your personal data, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your usage data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

Please do not supply any other person's personal data to us, unless we prompt you to do so.

Providing your personal data to others

We may share the personal data we collect from you in various ways. They include:

  1. Third-party service providers. We may disclose your personal data to our third party service providers and partners who provide IT and system administration services to us. This includes:

    • Mailchimp - we use Mailchimp for sending newsletters and facilitating competition fulfillments. You can unsubscribe from our newsletters at any time using the link at the bottom of the newsletter.
    • Gleam - we use Gleam for our competitions which captures user data for fulfilment purposes, for passing to our newsletter system, and for creating profiles of competition entrants. Please see Data Deletion Requests to request data deletion. Note that this deletion request only affects your data stored for Network N Media with Gleam. To delete all your Gleam data follow the instructions here https://gleam.io/help/account/how-do-i-delete-my-account
  2. Partners. If you enter a competition, we may disclose your personal details to the competition sponsor if you win in order that they can fulfil the prize. We may also disclose your personal data to any member of our group of companies: Project N, and Publisher Collective insofar as reasonably necessary for the purposes, and on the legal bases, set out in this policy.

  3. Advertising. We derive revenue from advertising to pay for the running and growth of our business, and to employ our staff. We use advertising networks to display advertising. This is facilitated by Publisher Collective Holdings Limited https://www.publisher-collective.com/, a global advertising platform of which we are a partner.

    We use technologies including Google Display Network Impression Reporting, auctions, DoubleClick Campaign Manager integration, Google Analytics Demographics, Permutive and others.

    We publish Google AdSense interest-based advertisements on our website. These are tailored by Google to reflect your interests. To determine your interests, Google will track your behaviour on our website and on other websites across the web using cookies.

    We use Avocet, OpenX, PulsePoint, Sovrn and Google Audiences to carry out retargeting and Header Bidding. These services use cookies for retargeting ads and targeting ads based on your interests. You can view the privacy policy of these service providers at http://avocet.io/privacy-policy, https://www.openx.com/legal/privacy-policy/, https://www.pulsepoint.com/privacy-policy.html, https://www.sovrn.com/privacy-policy/ and https://www.google.com/policies/privacy/.

    You can customise some of the advertising you see by visiting Google's My Ad Centre/My Ad Center. See our Cookie Policy for more information on how we use cookies.

  4. Analytics. We employ Google Analytics, Comscore and other technologies, including Parse.ly and Bing Webmaster Tools, for tracking user visits and behaviour on our websites. We use these to understand our audience and to monitor our website traffic. This technology may be used in conjunction with Google Ads to understand how site visitors interact with our site and advertising.

    Google's Privacy and Terms https://policies.google.com/technologies/partner-sites
    Bing's Privacy Statement https://privacy.microsoft.com/en-gb/privacystatement
    Parse.ly data privacy overview https://docs.parse.ly/privacy/

    Google Analytics and Comscore gather information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google's privacy policy is available at: https://policies.google.com/privacy. Comscore's privacy policy is available at https://www.comscore.com/About-comScore/Privacy-Policy

  5. Business transfers. We may share your personal data with third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

  6. Professional advisors. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

Where required by law or other specific scenarios. In addition to the specific disclosures of personal data we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

International transfers of your personal data

In this section we provide information about the circumstances in which your personal data may be transferred to countries outside the UK.

The hosting facilities for our website are situated in the US.

Many of our external third parties are also based outside the UK so their processing of your personal data will involve a transfer of data outside the UK. For example, Mailchimp may process personal data on our behalf in the US. Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.

You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use (or misuse) of such personal data by others.

Retaining and deleting personal data

This section sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

We will retain and delete your personal data as follows:

(a) Profile data for each newsletter subscription you have with us will be retained whilst you remain subscribed. Your profile data will be permanently deleted approximately one month after you have unsubscribed. Please note if you are subscribed to more than one newsletter your profile data will be retained for the subscribed newsletter list until you unsubscribe. You can also contact us to request deletion of data from all newsletter lists that we operate.

(b) Profile data for competitions will be retained until we receive a data deletion request. This is so that we can track your actions on our competitions, and for competition fulfilment purposes.

(c) Cookie data for advertising targeting and trafficking will be retained as per the Privacy Policy of https://www.publisher-collective.com/privacy-policy/

(d) Google Analytics 4 user and event data is retained for 14 months, with the retention date reset with each new event from the user.

Notwithstanding the other provisions we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

Your rights

In this section, we have summarised the rights that you have under data protection laws in relation to your personal data. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.

Your principal rights under data protection law are:

(a) the right to access. You have the right to confirm as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances. Provision of such information will be subject to the supply of appropriate evidence of your identity (for this purpose, we will usually accept a photocopy of your passport certified by a solicitor or bank plus an original copy of a utility bill showing your current address).

(b) the right to rectification. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.

(c) the right to erasure. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.

(d) the right to restrict processing. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.

(e) the right to object to processing. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.

(f) the right to data portability. You have the right to request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

(g) the right to request restriction of processing. You have the right to ask us to suspend the processing of your personal data in the following scenarios:

(h) the right to withdraw consent. You have the right to withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

You may exercise any of your rights in relation to your personal data by contacting us using the details outlined at the start of this privacy policy.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Data Deletion Requests

To request your user data be deleted please contact [email protected].

Please supply the email address associated with your data and/or any identifying codes (if you wish to delete data that we have captured using Permutive). If you no longer have access to the email for which we hold data please provide proof that you are authorised to request deletion for the email address supplied.

The Loadout and Starfield Db

Please note that the websites, Starfield Db and The Loadout are also subject to additional and/or alternate terms and conditions, privacy policy and cookie policies. You may find information about these at the following links:
https://www.venatus.com/terms-and-conditions
https://www.venatus.com/privacy-policy