1. INTRODUCTION

1.1 This website is owned and administered by Fidelity Media B.V., Binnendelta 18-B, 1261 WZ Blaricum, the Netherlands. Chamber of Commerce number 89354338.

1.2 The safeguarding of your data and privacy is a commitment and legal obligation from us owed to you and which we take seriously. This policy document, our ‘Privacy and Cookie Data Protection Policy’, applies when we are acting as the data controller or data processor of your information provided to us via use of our website or services.

1.3 The handling of your data is done in accordance with applicable laws pertaining to your jurisdiction, our policies comply with the EU General Data Protection Regulation (GDPR 2016/679) (hereinafter the “GDPR”) for individuals and organizations within EU member states and those within the European Economic Area.

1.4 Personal data is defined by the GDPR as: “any information relating to an identified or identifiable natural person ('data subject'); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person".

1.5 For a copy of this policy in a different format or to raise any concerns or queries please contact Company Data Protection Officer by email at [email protected] will be able to assist.

2. DATA PROCESSOR

2.1 This Privacy & Cookie Policy sets out the way in which Fidelity Media B.V. will handle your data as the ‘Data Controller’ including any personal information relating to you from the use of our services. Use of our services includes but is not limited to any consultation, purchase, enquiries or other activities which require the sharing of information between you and us.

3. DATA COLLECTION

3.1 Any data handled by us as the data processor will be strictly treated in accordance with this policy including any data provided from you to us via https://fidelity-media-minds.com. Fidelity Media B.V. will never sell, provide license to or transmit your personal data without first obtaining express consent from you in writing.

4. LEGAL BASIS OF COLLECTING PERSONAL INFORMATION

4.1 As a company operating in The Netherlands we may only collect personal data where and when we have a legal basis to do so. Examples of this include:

• We have contractual obligations to you that requires the use of such data;

• You consent to our processing and handling of your data;

• In accordance and compliance with privacy laws and regulations of the applicable jurisdiction.

5. CATEGORIES OF PERSONAL INFORMATION HELD

5.1 Throughout the course of our work, we collect personal data and information in our interactions with you through your use of our website and through other communications. Typical types of information we process from you include but are not limited to your name, email address, IP address, location, physical address, and that which arises during our correspondence. We will always comply with the domestic and international laws applicable and therefore personal information may too be used to achieve that.

6. PURPOSES FOR USING YOUR PERSONAL INFORMATION

6.1 You are entitled to know the purposes for which we would process your data and for us to be clear and transparent. Our legitimate purposes are:

• To provide you with appropriate customer support;

• General operation of our services and website;

• To maintain our relationships with you as a customer and to communicate with you as appropriate;

• To inform us on the way in which our services are being used by our customers;

• To maintain and improve our web services by using analytical data;

• We may retain and utilise information provided to us by you in the event of any legal claim;

• To inform any future marketing our customer outreach to ensure only relevant information is sent to customers;

• To counteract fraud or illegal activity being directed at our website.

7. COLLECTING PERSONAL DATA

7.1 Our website uses cookies, tags and other similar kinds of technology on our website this includes third-party data service providers. We are in no way liable or responsible for the actions of third-party providers. These are used to make your experience of using our website easier and to provide us with information about who uses our website. You can disable cookies by using your browser settings or by declining to accept cookies when you first visit our website. We will only use cookies when necessary and a legitimate interest exists in processing your data. All our employees are explicitly instructed only to collect and process data relevant in the course of their employment and in the serving of customers.

8. DATA SHARING WITH OTHER PARTIES

8.1 From time to time Fidelity Media B.V. may work with third-party data service providers who we will share data with to perform a specific function.

8.2 Any data sharing relationship between us and a third-party provider will be subject to a data sharing agreement with appropriate safeguards included in our contractual relationship with them.

8.3 Any data shared with a third-party provider is for a specified purpose and no third-party provider has a separate independent right to utilise such data in any other way.

8.4 Using our website, you acknowledge that the information you provide can through malicious acts be available to other users of the internet. We agree to use best endeavours through appropriate software and procedures to prevent any data breach.

8.5 Any Financial transactions used through our website or services involves sharing of data with our financial provider. We will only share this information to the extent required, typically that includes payments processing, refunds and answering any queries relating to a payment.

8.6 We will only share or transfer personal information as described and under the conditions set out in this section.

9. PRIVACY RIGHTS

9.1 Under GDPR you have specific rights relating to your data. Nothing in this policy infringes those rights, the rights provided by Article 13(2) of the GDPR are as follows to you as a data subject. These include the following rights:

• The right to access your data, you can ask for copies of data we hold;

• The right to rectification which permits you to ask us to amend your data;

• The right to withdraw consent and thereby withdrawing the legal basis by which we hold your data;

• The right to limit the use of your data including the right to object to the processing of your data;

• The right to the full deletion of your data, commonly known as the ‘right to erasure’;

• The right to complain to your appropriate national authority about how we handle your data.

The above rights are subject to specific limitations and exceptions you can find these here.

10. EXERCISING YOUR RIGHTS

10.1 Should you wish to exercise any of the rights in Section 8, in the first instance please contact Company Data Protection Officer by email at [email protected] who will be able to assist. Verification of your identity will be required to comply with the applicable data law.

11. DATA RETENTION

11.1 Any data collected will be retained for no longer than necessary. Data that is collected because of cookies or tracking is retained for a short period of time, unless it is being used in consideration of website security or general improvement to our services.

11.2 Any enquiries from you will be stored for a maximum of six months following the query being concluded, email and contact data will be deleted should you unsubscribe or notify us you no longer wish to hear from us.

11.3 Where personal data is required for the use in legal proceedings, we reserve the right to retain this information for the period of legal proceedings.

12. SECURE HANDLING OF YOUR DATA

12.1 Fidelity Media B.V. has a general obligation to ensure its handling of your data and personal information is done so in a vigilant manner to protect against illegal or unauthorised access, disclosure or use. In the event of a data breach that may affect you we will notify you through the main contact information you have provided. Fidelity Media B.V. is not responsible for any negligence in protecting your own data or information concerning our services.

13. THIRD-PARTY WEBSITES

13.1 Links to external websites that are not under our control may pose a risk to your data security. We do not assume and are not liable for any content on external websites. You should consider the Privacy Policy of any external website before using it with due regard to your own information security.

14. AMENDMENTS TO THIS POLICY

14.1 From time to time, we may update this policy, if we do so we will publish the new policy on our website and the date the policy was implemented will be marked clearly on the webpage. In the event of significant changes that we consider may affect you we may notify you by email. Your continued use of our website and services implies that you agree to operate our website under the current version of our Privacy and Cookie Policy.