CPD HUB AND DIRECTORY SERVICES PRIVACY NOTICE
INTRODUCTION
This Privacy Notice explains what Personal Data Fundamental Media Limited processes in connection with our CPD HUB Services. It also explains why and how we process that data together with the protections we have in place to keep it secure.
ABOUT US
Fundamental Media Limited is a company registered in England and Wales and is the parent company within the Fundamental Group (“Fundamental”, “us” “we” or “our”). We operate as a specialist media agency providing our clients with media planning and buying expertise, together with media intelligence. Further detail about what we do is set out below. Our contact details are set out below. Our corporate website is www.fundamentalgroup.com where our Privacy Policy is set out in full, and this contains, amongst other information, details of your rights in relation to any personal data we process about you.
OUR SERVICES
(A) CPD HUB
CPD HUB, our proprietary web-based tool, provides a source of CPD Materials for you to access and online tools for you to record the CPD you undertake. Access to the application requires that users register, providing their details and contact information prior to use. This information, including, the user’s name, company name, job title, telephone number and email address is used to enable us to administer accounts and monitor usage (where applicable). This personal data is securely stored on servers located within the United Kingdom and processed as a necessary part of providing the CPD HUB Services and performing our contract for CPD HUB Services.
Fundamental acts as Data Controller in processing personal data submitted to or obtained via your use of CPD HUB.
CPD Materials are made available by our “Content Partners” and are accessed via their (third -party) websites. We therefore recommend that you read their privacy policies and website terms and conditions on accessing their websites, as we are not responsible for their content.
(B) DIRECTORY SERVICES
In addition, on signing up for our CPD HUB services eligible users may also elect to receive our Directory Services (inclusion of their profile information on a searchable online directory of professional advisors. User contact details and profile information are only published to this online directory where you elect to receive these services from us. The Personal Data which is shared is controlled by you the “Directory User” in your account and can be changed, amended or removed by making the necessary changes to your account. If you elect to receive the Directory Services, we will process the contact details and profile information you provide in your account by publishing this to our online searchable Directory as is necessary to provide these services to you.
HOW IS YOUR DATA USED
Our Use
We collect certain Personal Data when you register for a CPD HUB account as is necessary to record and administer your contract with us to use our CPD HUB services and to provide you with service updates and developments to the CPD HUB Platform (“Service Updates”). In addition, we may contact you with news and content that may be of interest on the platform or with connected product offerings (“Content Updates”). If you would prefer not to receive Content Updates, please opt out of these on registration or update your preferences within your account.
With your consent, we use cookies to understand how you use our CPD HUB services, what topics are of interest, learning behaviours as well as how our website is navigated so as to (i) improve our services (ii) use that data to provide targeted advertising on our behalf (the Fundamental Group) and behalf of our clients. We ask for that consent via our cookie consent tool which displays on accessing CPD Hub. Please note that these preferences can be changed at any time via the cookie consent tool.
We also use the Alphix Tag which enables us to (i) carry out website visit fraud verification and analysis of “bot” activity (ii) generate company-level insights about corporate visitors to our website and (iii) retarget and advertise to those corporates visiting our website via their company-owned IP address (firmographic targeting). The Alphix Privacy Notice explains how the Alphix Tag works, the information we collect and approach we take. With the Alphix Tag we do not seek to process any data which is directly or indirectly capable of identifying any individual visitor to our website. The solution does not rely on cookies and individual users are not tracked. We recognise that the mere collection of IP addresses raises the question of whether personal data is in fact processed. In that vein, we (as data controller) have a legitimate interest in processing Alphix data where it comprises personal data for the purposes listed above.
Content Partner Use
We also provide analysis to our Content Partners regarding our users’ areas of interest, popular content and learning behaviours. Such information is a supplied to our Content Partners in a non-personally identifiable and aggregated manner.
In addition, we may pass your contact details on to named Content Partners so that they may market products and services of interest to you, where we have your consent to do so. We would also like to share details of your use of CPD HUB with our Content Partners, such as which articles you have read and completed and which pages you have viewed so that their marketing material can be as relevant to you as possible, but we will only share this with your consent in each case. We will seek these consents on behalf of our Content Partners on appropriate web-pages. No personal data will be shared without your consent. We recommend that you read the privacy policy of any named Content Partner before consenting to share any personal data. On termination of your account with us we will securely delete any Personal Data you have submitted. Please note that prior to terminating your account, you should download or print your CPD records as we do not archive terminated accounts and your CPD records may not be available following termination.
Please note that you can change your preferences regarding our use of your personal data at any time by amending your cookie preferences. Likewise, you may change your preferences in relation to our sharing of your personal data with Content Partners, by changing the permissions you provide on the Content Partner’s dedicated CPD Hub web-page.
Alternatively, in relation to our use of your personal data to provide advertising services based on your browsing activity on CPD HUB, you may adjust your browser settings. You can learn how to do this by viewing the browser’s help menu, or you can do to the Digital Advertising Alliance’s consumer choice page http://www.youronlinechoices.com. You may also clear your browser cache or reset your cookies, but you should remember that this does not present cookies from being place on your device in the future. In any case you should review the privacy policy of the website you are visiting.
Additional Features
CPD HUB offers additional optional features, including the CPD HUB Browser Extension (the “Extension”). The Extension enables you to readily capture and record the web-pages you visit to support your learning records (the “Browser Extension Services”), as displayed in you CPD HUB account, by recording the url visited, time, date and duration of your visit (“Browser Data”). It also enables us, as part of the Browser Extension Services, to provide you with recommended content The Browser Extension is to be used to support learning and professional activities and should not be used in connection with browsing pages, content or materials which would reveal any sensitive personal data about you. Web-pages are only tracked and Browser Data is only recorded by CPD HUB where you actively and explicitly opt to receive this functionality; and you may withdraw your consent at any time. Where you elect to receive the Browser Extension Services, you can tailor the information recorded to support your learning. You may elect to record (i) all pages visited in order to capture all potential leaning activity, or (ii) whitelisted pages visited (as pre-identified by CPD HUB as likely to support your learning) or (iii) manually selected pages visited (as preidentified by you). FML uses the Browser Data (i) to provide, support and develop the Browser Extension Services, (ii) to support the development of other Fundamental Group products and services and (iii) to build tailored audiences for marketing activities. If you would prefer that your Browser Data not be used for (ii) and (iii) please make the appropriate selection on installation of the Extension, or you may alter its settings at any time. Please note that Browser Data is not shared outside of the Fundamental Group, save as is necessary to provide the services. This data is held securely on servers located in the UK.
For more information on your rights, please see the “Your Privacy Rights” section of our Privacy Policy here.
CONTACTING US
By Email: [email protected]
By post:
The Privacy ManagerFundamental Media Limited
100 Cannon Street
London EC4N 6EU
Changes to this Notice
We may change this Notice from time to time to reflect any changes to the types of Personal Data we process or how this processing takes place. We will notify you of any material change to this Notice.
Updated 30 November 2022.