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PRIVACY POLICY

Gruppo Media Limited (Gruppo) is the company behind Rouleur - we respect your privacy and are committed to safeguarding your personal data. The following information will lay out how we look after your personal data when you visit or use any of our sites or apps, including but not limited to Rouleur.cc, Rouleurclassic.cc, Rouleur.imbmsubscriptions.com as well as any of our social media pages (including, but not limited to, Facebook, YouTube, Instagram and Twitter) which are collectively referred to here as the Platforms and tell you about your privacy rights and how the law protects you.
At the end, there is a glossary to understand the meaning of some of the terms used in this privacy policy.


PURPOSE OF THIS PRIVACY NOTICE


This privacy notice aims to give you information on how Gruppo collects and processes your personal data through your use of the Platforms, including any data you may provide for example when you sign up to our newsletter, purchase a product or service or take part in a competition.
 The Platforms are not intended for children and we do not knowingly collect data relating to children.
 It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.


CONTROLLER


Effectively, Rouleur is Gruppo Media Limited, we are an independent publisher, retailer and events provider. This privacy notice is issued on behalf of Gruppo Media so when we mention “Gruppo Media”, "we", "us" or "our" in this privacy notice, we are referring also to Rouleur. We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights in respect of your personal information, please contact us using the details set out below.


CONTACT DETAILS


Our full details are:

Legal entity: Gruppo Media Limited


DPO: In-house Counsel


Email address: info@rouleur.cc

Postal address: 47 Bermondsey Street, London, SE1 3XF

Please contact us before exercising your right to make a complaint to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk) - we will do our best to resolve any concerns you may have. We are a small company trying to do things the right way.


CHANGES TO THE PRIVACY POLICY


It is important that the personal data we hold about you is accurate. Please keep us informed if your personal data changes so that we can continue to serve you as expected. As regulations change, Gruppo Media may update this policy at any time, so please check this page regularly to ensure you are kept up–to–date. If we make any big changes that would affect our relationship with you, we let you know in advance.


LINKS TO THIRD-PARTY


This Platform 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 any of our Platforms, we encourage you to read the privacy notice of every website you visit.


WHAT WE COLLECT FROM YOU


Your personal data means any information from which you can be identified. It does not include data where your identity has been removed (anonymous data) or is not attached.
 In going about our business, we might collect, use, store and transfer various kinds of your personal data. We've grouped those types of data together as follows:

  • ID Data includes your name, or other identifier, title, date of birth and gender.
  • Contact Data includes billing address, shipping address, email address and telephone numbers.
  • Transaction Data includes details about payments and other details of products and tickets you have purchased from us.
  • Technical Data includes your internet protocol (IP) addresses, login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform plus the devices you use to access our Platforms.
  • Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and any third parties (where applicable).
  • We do not collect any Special Categories of Personal Data about you (which includes details about race or ethnicity, religious or philosophical beliefs, political opinions etc).


    IF WE ARE MISSING PERSONAL DATA


    Sometimes we might need to collect personal data by law, or in order to fulfil a contract we have with you. If that data is not provided when requested, we may not be able to fulfil the contract we have or are trying to enter into with you (for example, to send you the magazine or a product you have ordered). We will use our best endeavours to source the details from you, but we may have to cancel a product or service you have with us if unsuccessful.


    HOW DO WE COLLECT YOUR DATA?


    There are lots of ways in which data is collected such as:

    Direct communication - You may give us your ID, Contact, Profile and Marketing and Communications Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

  • Purchase our products or services (including a membership);
  • Create an account on our Platforms;
  • Request marketing or newsletters to be sent to you;
  • Enter a competition, promotion or survey; or
  • Give us some feedback.
  • Automated technologies or interactions - As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We use cookies, server logs and other similar technologies, and we may also receive Technical Data about you if you visit other websites (such as Facebook) employing our cookies.

    Third parties or publicly available sources - Although we don't buy in data, we may receive personal data about you from various third parties and public sources as set out below:

    Technical Data from the following parties:

  • Analytics providers such as Google or Buffer;
  • Search information providers.
  • Contact and Transaction Data from providers of technical, payment and delivery services such as Paypal, based inside the EU.


    OTHER DATA


    Your interactions with third party platforms on our Platforms, will be governed by the privacy terms of that third party, and we are not responsible for such interactions or for additional personal information you may decide to provide to such third parties. You are strongly advised to read any relevant third party's privacy and cookie policies prior to any such interaction.


    HOW WE USE YOUR PERSONAL DATA


    We will only use your personal data when the law allows us to. The following circumstances are examples of how we most commonly use your data:

  • Where we need to fulfil the contract we are entering into or have entered into with you.
  • Where it is necessary for our legitimate interests (if you have purchased something from us) and your interests and fundamental rights do not override those interests.
  • Where you have opted in to receive communications from us, for example newsletters.
  • Where we need to comply with a legal or regulatory obligation.

  • You have the right to withdraw consent to marketing at any time by Contacting us in accordance with the details above, or you can unsubscribe from any email. Mostly our audience has given us explicit consent, but we also send communications to people who have purchased our goods and services.


    MARKETING


    We try to provide you with choices regarding how we use your personal data, particularly around marketing and advertising - we are a business, but you have the right to privacy. 
Like other businesses, we may target ads to you when you are on other websites and apps. We do this using a variety of delivery methods, and we use a range of advertising technologies like web beacons, pixels, ad tags, cookies, and mobile identifiers, as well as email and platform specific services offered by some sites and social networks, (for example Facebook’s Custom Audience service). In many cases, the ads you see will be based on information we hold about you, or your previous use of our Platforms and communications. We may also use services such as those provided by MailChimp in order to contact you about items you have looked at or placed in a shopping cart if you do not proceed to complete a purchase. MailChimp and other such providers employ the use of cookies, unique identifiers, web beacons and similar tracking technologies to keep tabs on things like open rates and conversion rates. You may unsubscribe from such emails (which will include an unsubscribe link), or alternatively follow the steps in the ‘opting out’ section below.


    We may use your data to suggest what may be of interest to you and present them to you. 
You may receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or if you have opted in to receiving a newsletter from one of our Platforms and, in each case, you have agreed to receive that marketing.


    THIRD-PARTIES


    We will not share your personal data with any company outside Gruppo Media for marketing purposes unless you explicitly give permission for us to do so.


    OPTING OUT


    You can ask us to stop sending you marketing or newsletter messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time. 
Where you opt out of receiving such messages, this will not apply to personal data provided to us as a result of a product/service purchase, experience or other transactions.


    COOKIES


    Gruppo Media’s Platforms (including our websites) use a number of “cookies”, which are small text files placed on your computer with your consent, to help us understand your use of the site, to store your preferences (where expressed), and to provide services and offers that we think may better suit your needs or be of interest you. When you visit one of our Platforms, you may see a cookie banner displayed. By continuing browsing or other use of a Platform, you agree to our use of cookies, in accordance with our cookie policy.
 Gruppo Media also uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help the website analyse how people use our Platforms. The information generated by the cookie about your use of the Platforms (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google. By using our Platforms, you consent to the processing of data about you by Google in this manner and for the purposes set out above.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. 
Please note that third parties (including for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, which we are not responsible for and over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies. Accordingly, when you view and interact with our content on other platforms, including for example on Facebook, Instagram, Twitter and YouTube, those platforms may also use cookies.


    CHANGE OF PURPOSE


    We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. 
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.


    DISCLOSURES OF YOUR PERSONAL DATA


    We may have to share your personal data with the parties set out below.

  • Internal Third Parties as set out in the Glossary.
  • External Third Parties as set out in the Glossary.
  • 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 notice.
  • 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


    Generally, we do not transfer your personal data outside the European Economic Area (EEA), and we will not do so unless this is absolutely necessary. Some of our our external third parties may be based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.
  • Where we use certain service providers based outside the EU, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.
  • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

  • DATA SECURITY


    We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
 We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.


    DATA RETENTION


    We will only keep your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. 
The appropriate retention period for personal data depends on the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
 By law we may have to keep certain basic information about our customers (including Contact, Identity and Transaction Data) for six years after they cease being customers for tax or other compliance purposes.
 In some circumstances you can ask us to delete your data: see Request erasure below for further information. 
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.


    YOUR LEGAL RIGHTS


    Under law, you have the right to:
 Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.


    Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.


    Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.


    Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.


    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.

    
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.

    WHAT WE MAY NEED FROM YOU


    We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.


    TIME LIMIT TO RESPOND


    We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex, if you have made a number of requests, or if for example we need to further clarify the basis of your request or contact you for evidence of identity. In this case, we will notify you and keep you updated.


    GLOSSARY

    Lawful basis - Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.


    Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.


    Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.


    Third Parties:

  • Service providers, including Amazon Web Services and Google Cloud Platform, whose servers are based within the EU and who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the United Kingdom who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers, generally based in the United Kingdom who require reporting of processing activities in certain circumstances.
  • Organisations providing remarketing services (including Google and Facebook). Using tracking cookies enables relevant ads to be served to users based on past visits to our Platforms, including our websites. You can opt out of the use of these cookies at any time by changing your settings in the relevant parties’ ad settings.
  • Other providers which we contract with in respect of our online shop and subscription services, and which provide online fulfilment services and order processing/warehouse management provider. We may pass certain of your personal information to these third parties as is required to facilitate delivery and management of your order or subscription (currently Green Snow Online Fulfilment Limited (order processing), Realtime Despatch Software Limited (warehouse management)), Intermedia Brand Marketing Ltd and IMS (subscription fulfilment). We are careful to ensure that any personal information processed by these providers is limited insofar as possible and that appropriate security measures are in place to ensure the safety of your information.