Privacy Policy

  1. Introduction

    • Hoxo Media Limited (referred to as “we”, “us” and “Hoxo Media”) is committed to protecting and respecting your privacy. This privacy policy (the “Privacy Policy”) informs you how we look after your Personal Data (as defined below) when you visit our website (https://hoxomedia.com) (regardless of where you visit it from) and any other applications published by us from time to time (together, the “Website”) and otherwise access our Services. This Privacy Policy also tells you about your privacy rights and how the law in our jurisdiction protects you.
    • Please take the time to read and understand this Privacy Policy, together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing Personal Data, carefully to understand our views and practices regarding your Personal Data. This Privacy Policy supplements the other notices and is not intended to override them.
    • The Website is not intended for children and we do not knowingly process Personal Data relating to children.
    • By visiting the Website and/or using our Services you are accepting and consenting to the practices described in this Privacy Policy.

 

  1. Terminology

    • Below is some quick guidance on terminology used in this Privacy Policy:

Anonymous Data means Personal Data that has been amended to the extent that it no longer contains any identifying information and thus no longer constitutes Personal Data;

Children means any persons under the age of 18;

Cookies has the meaning given in Section 13 of this Privacy Policy;

Data Controller means the natural or legal person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any Personal Data are, or are to be, processed as outlined in the Data Protection Legislation;

DPO means data protection officer;

Data Protection Legislation means all applicable data protection and privacy legislation in force from time to time in the UK including the General Data Protection Regulations ((EU) 2016/679); the Data Protection Act 2018; the Privacy and Electronic Communications Directive 2002/58/EC (as updated by Directive 2009/136/EC) and the Privacy and Electronic Communications Regulations 2003 (SI 2003/2426) as amended;

Device has the meaning given in Section 13 of this Privacy Policy;

ICO means Information Commissioner’s Office which is the UK regulator for data protection purposes;

Personal Data has the meaning given to it in the Data Protection Legislation and is any information relating to an identified or identifiable living person. Personal Data includes Special Categories of Personal Data;

Services means all those services provided by us to you including without limitation personal brand management, company branding services, ghost-writing, one-to-one coaching, online seminars, provision of recorded content, social media management and marketing.;

Special Categories of Personal Data means information revealing racial or ethnic origin, political opinions, religious or similar beliefs, trade union membership, physical or mental health conditions, sexual life, sexual orientation, biometric or genetic data;

Terms means each of the terms of use of our Website and any specific terms provided to you when you contract for Services;

Usage Data has the meaning given in Section 5 of this Privacy Policy.

  • Capitalised terms used in this Privacy Policy but not defined above shall have the meaning given in the Terms.

 

  1. Purpose of this Privacy Policy

    • This Privacy Policy (together with our Terms and any other documents referred to in it) sets out:
    • the basis on which Hoxo Media as Data Controller collects any Personal Data from you; and
    • how any Personal Data that you or any other person provides to us will be processed by us.
    • This Privacy Policy applies to Personal Data provided to us, both by individuals themselves and by others.
    • We may use Personal Data provided to us for any of the purposes described in this Privacy Policy or as otherwise stated at the point of collection.
    • When collecting and using Personal Data, our policy is to be fair, lawful and transparent about why and how we process Personal Data.
    • We have security measures in place designed to prevent the loss of data, preserve data integrity, and to control access to the data as we know that ensuring the accuracy and security of your Personal Data is essential to retaining your confidence and trust.

 

  1. Important information and who we are

    • This is the Privacy Policy for https://hoxomedia.com and any other applications constituting the Website. The Website is operated by or on behalf of Hoxo Media. This Privacy Policy is also applicable to any Personal Data collected and/or processed by us in the course of interactions with you other than through the Website.
    • For the purposes of the Data Protection Legislation, when you access the Website or otherwise provide us with Personal Data we are acting as the Data Controller and we are responsible for your Personal Data. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact us using the details set out in clause 23.
    • We are registered under the Data Protection Act 2018 with the Information Commissioner’s Office (the UK supervisory authority for data protection issues) (the “ICO”). Our registration number is ZB218438.
    • By accessing or using the Website, purchasing Services from us or otherwise interacting with us:
  • you acknowledge and consent to the collection and use of your information in accordance with this Privacy Policy; and
  • you agree that we may treat your in Personal Data as set out in this Privacy Policy.
    • If you do not agree with any of the provisions of this Privacy Policy, you should refrain from using the Website or the Services immediately.

 

  1. Personal Data we may collect from you

    • Personal Data 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).
    • We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together as follows:

(a)            Identity Data includes first name, maiden name, last name, profile photo, username or similar identifier, marital status, title, date of birth and gender.

(b)           Contact Data includes address for services, email address and telephone numbers.

  • Financial Dataincludes bank account and payment card details.
  • Transaction Dataincludes details about payments to and from you.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access the Website.
  • Account Data includes your username and password, your interests and preferences.
  • Usage Data includes information about how you use the Website products and services, including but not limited to, traffic data and other communication data, referral source/ exit pages, length of visit, page views, Website navigation, search terms you use and the resources you access.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
    • We may also collect, use and share aggregated data such as statistical or demographic data for any purpose. Aggregated data may be derived from your Personal Data but is not considered Personal Data in law as this data does not directly or indirectly reveal your identity (Anonymous Data). 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 Identity 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.

 

  1. How is your personal data collected?

    • We use different methords to collect data from and about you including through:
  • Direct interactions. You may give us your Identity and Contact Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes Personal Data you provide when you:
    • sign up for our Services;
    • create an account on the Website;
    • request marketing to be sent to you;
    • enter a competition, promotion or survey;
    • give us feedback; or
    • contact us.
  • Automated technologies or interactions. As you interact with the Website, we will automatically collect Technical Data about your equipment, browsing actions and patterns, and Usage Data about your actions on the Website. We collect this data by using Cookies, server logs and other similar technologies. We may also receive Technical Data and Usage Data about you if you visit other websites employing our Cookies.
  • Third parties or publicly available sources. We will receive Personal Data about you from various third parties and public sources as set out below:
  • Technical Data from the following parties:
    1. analytics providers based inside and outside the UK;
    2. advertising networks; and
  • Financial and Transactional Data from providers of technical and payment services; and
  • search information providers based inside and outside the U

 

  1. The legal grounds for processing your Personal Data

    • The legal grounds for processing your Personal Data under Data Protection Legislation are:
  • the performance of a contract with you;
  • where it is necessary for our legitimate interests (including fraud prevention, child protection, maintaining quality of service, error detection and cybersecurity);
  • consent (where we have secured explicit, freely given, positive affirmation of consent); and
  • where we need to comply with a legal or regulatory obligation.
    • Generally, we do not rely on consent as a legal basis for processing your Personal Data although we will request your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

 

  1. Purposes for which we will use your personal data

    • We have set out below a description of all the ways we plan to use your Personal Data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are, where appropriate.
    • We may process your Personal Data for more than one lawful ground, depending on the specific purpose for which we are using your Personal Data. Please contact us if you need details about the specific legal ground we are relying on to process your Personal Data, where more than one ground has been set out in the table below.
    • For the avoidance of doubt, this table is not exhaustive of the ways in which we may use your Personal Data, and there may be occasions where we require additional information.

 

Purpose/Activity

Type of Data

Lawful Basis for Processing Including Basis of Legitimate Interest

If you contact us

    (a)            Identity Data

    (b)            Contact Data

    (c)            Technical Data

Necessary for our Legitimate Interests (to communicate with you, develop our Website and grow our business).

To enable you to use our Services and register you as a member.

    (a)            Identity Data

    (b)            Contact Data

    (c)            Usage Data

    (d)            Account Data

    (e)            Marketing and Communication Data

     (f)            Financial Data

    (g)            Technical Data

(a) Performance of a contract with you; and

(b) Necessary for our legitimate interests (to provide our Services to users, maintaining quality of service).

To manage payments, fees and charges and collect and recover money owed to us.

    (a)            Identity Data

    (b)            Contact Data

    (c)            Account Data

    (d)            Financial Data

(a) Performance of a contract with you; and

(b) Necessary for our legitimate interests (to recover debts due to us).

To manage our relationship with you which may include notifying you about changes to our Terms or Privacy Policy or asking you to leave a review or take part in a survey

    (a)            Identity Data

    (b)            Contact Data

    (c)            Usage Data

    (d)            Account Data

    (e)            Marketing and Communication Data

(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

To identify if you have notified us that you do not wish to be contacted and/or receive direct marketing information regarding the Services or any other activities.

    (a)            Identity Data

    (b)            Contact Data

    (c)            Usage Data

    (d)            Account Data

(e) Marketing and Communication Data

 Necessary to comply with a legal obligation.

To contact you directly in the future regarding our Services or any other activities or make suggestions and recommendations to you.

 

    (a)            Identity Data

    (b)            Contact Data

    (c)            Technical Data

    (d)            Usage Data

    (e)            Account Data

(f) Marketing and Communication Data

Necessary for our legitimate interests (to develop our products and our Services and grow our business in a way that is compatible with the preferences of users, to provide advertisements).

To identify any suspicious activity, fraud or error detection.

    (a)            Identity Data

    (b)            Contact Data

    (c)            Usage Data

    (d)            Account Data

    (e)            Marketing and Communication Data

     (f)            Financial Data

(e)        Transaction Data

 

(a) Performance of a contract with you;

(b) Necessary for our legitimate interests (for the efficient running of the Website and our Services, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and

(c) Necessary to comply with a legal obligation.

To administer and protect our business and the Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).

    (a)            Identity Data

    (b)            Contact Data

    (c)            Technical Data

    (d)            Usage Data

(e)           Account Data

(a) Necessary for our legitimate interests (for the efficient running of our Services, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); and

(b) Necessary to comply with a legal obligation.

To use data analytics to improve our website, products/Services, marketing, customer relationships and experiences.

    (a)            Technical Data

    (b)            Usage Data

    (c)            Account Data

 

Necessary for our legitimate interests (to define types of customers for our products and Services, to keep our website updated and relevant, to develop our business, products and our Services and to inform our marketing strategy).

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

    (a)            Identity Data

    (b)            Contact Data

    (c)            Usage Data

    (d)            Account Data

    (e)            Marketing and Communication Data

     (f)            Financial Data

    (g)            Transaction Data

 

Necessary for our legitimate interests (to study how customers use our products and our Services, to develop them, to grow our business and to inform our marketing strategy)

To create Facebook audiences and to retarget advertising using social media platforms

    (a)            Usage Data

    (b)            Account Data

    (c)            Marketing and Communication Data

    (d)            Transaction Data

    (e)            Technical Data

Necessary for our legitimate interests (to promote our business)

 

  • We will only use your Personal Data lawfully and 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 receive 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 or request your consent.
  • 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.

 

  1. MARKETING

    • We strive to provide you with choices regarding certain Personal Data uses, particularly around marketing and advertising.

 

Promotional offers from us

  • We may use your Identity, Contact, Technical, Usage and Account Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

 

Third -party marketing

  • We will get your express opt-in consent before we share your Personal Data with any third party for marketing purposes.

 

Opting out

  • You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

 

  1. How long we retain your data

    • How long we keep information we collect about you depends on the type of information and how we collect and store it. After a reasonable period of time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
    • We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as needed to comply with our legal obligations, resolve disputes and enforce our agreements).
    • When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information at an earlier date if you so request, as described in the section “Privacy Rights and Choices” below.
    • If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or ceased using your HubSpot account.  We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.

 

  1. Third party links

The Website may feature 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 notices. When you leave the Website, we encourage you to read the privacy notice of every website you visit.

 

  1. Disclosure of your information to third parties

    • We may share your information with selected third parties, including but not limited to:
  • our business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
  • advertisers and advertising networks that require the data to select and serve relevant adverts to you and others. We do not disclose Personal Data about users to our advertisers, but we may provide them with aggregate information or Anonymous Data about our users. We may also use such aggregate information or Anonymous Data to help advertisers reach the kind of audience they want to target. We may make use of Personal Data we have collected from you to enable us to comply with our advertisers’ wishes by displaying their advertisement to that target audience; and
  • analytics and search engine providers that assist us in the improvement and optimisation of the Website.
    • We may disclose your Personal Data to third parties:
    • in the event that we sell or buy any business or assets, in which case we may disclose your Personal Data to the prospective seller or buyer of such business or assets;
    • if Hoxo Media or substantially all of its assets are acquired by a third party, in which case Personal Data held by it about its users will be one of the transferred assets; and
    • if we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Terms and any other agreements we may have with you, or to protect the rights, property, or safety of Hoxo Media, our users, or others. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
    • 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.

 

  1. Where we store your Personal Data

All information you provide to us (except payment information) is stored on secure servers. Any payment information you provide to us is stored on secure servers provided by our payment provider.

 

  1. Changes to your Personal Data

It is important that the Personal Data we hold about you is accurate and up-to-date. Please keep us informed if your Personal Data changes during your contract with us.

 

  1. Cookies

    • In order for us to improve the Website, we use small files commonly known as “Cookies” to track your visit. A Cookie is a small amount of data which often includes a unique identifier that is sent to your computer, tablet or mobile phone (referred to in this Privacy Policy as a “Device”) from a website and is stored on your Device’s hard drive. A Cookie records information relating to your internet activity (such as whether you have visited the websites before). This information is used to track visitors’ use of the Website and to compile statistical reports on Website activity. The Cookies we use and those of our chosen third parties also allow us to identify you as you move around the Website and when you return. By continuing to browse the Website, you are agreeing to our use of Cookies.
    • You may refuse the use of Cookies by adjusting your internet browser settings not to accept Cookies. Your web browser’s help function should tell you how to do this. Alternatively, to find out more about Cookies, including how to see what Cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org. This website will also explain how you can delete Cookies which are already stored on your Device. Please note that if you refuse the use of Cookies you may not be able to use the Website.
    • We use the following Cookies:
  • strictly necessary Cookies. These are Cookies that are required for the operation of the Website. They include, for example, Cookies that enable you to log into secure areas of the Website, use a shopping basket or make use of e-billing services;
  • analytical/performance Cookies. These allow us to recognise and count the number of users and to see how users move around the Website when they are using it. This helps us to improve the way the Website works, for example, by ensuring that users are finding what they are looking for easily;
  • functionality Cookies. These are used to recognise you when you return to the Website. This enables us to personalise our content for you, greet you by name and remember your preferences; and
  • targeting Cookies. These Cookies record your visit to the Website, the pages you have visited and the links you have followed. We will use this information to make the Website and the advertising displayed on it more relevant to your interests. We may also share this information with third parties for this purpose.
    • Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use Cookies, over which we have no control. These Cookies are likely to be analytical/performance Cookies or targeting Cookies. You are able to block Cookies by activating the setting on your browser that allows you to refuse all or some Cookies. However, if you block all Cookies (including essential Cookies), you may not be able to access all or parts of the Website.

 

  1. If you fail to provide Personal Data

Where we need to collect Personal Data by law, or under the terms of a contract we have with you and you fail to provide that Personal Data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our Services). In this case, we may have to cancel a product or the Services you receive from us, but we will notify you if this is the case at the time.

 

  1. 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.

 

  1. Your rights

    • Under certain circumstances, you have rights under Data Protection Legislation in relation to your Personal Data.
    • 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, for example, where you consider that we do not need it any longer for the purposes for which we originally collected it as explained to you in this Privacy Policy, where you have withdrawn your consent to our using it and we had relied on that consent according to this Privacy Policy, where you consider that we cannot show a ‘legitimate interest’ in continuing to process it and we have relied on that legitimate interest to process it as explained to you in this Privacy Policy. 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 Data Protection Legislation. Please 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. You have the right to 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:
      • if you want us to establish the data’s accuracy;
      • where our use of the data is unlawful but you do not want us to erase it;
      • 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
      • 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. Please 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; and
    • 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.
    • 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 may refuse to comply with your request in these circumstances.
    • If you wish to exercise any of the rights, please contact us and mark your query for the attention of the DPO.

 

  1. International transfers

.

 

  1. Statutory or contractual requirement

The provision of your Personal Data is not a statutory or contractual requirement, or a requirement necessary to enter into a contract, nor are you obliged to provide the Personal Data, however without the data mentioned in this Privacy Policy it will not be possible to benefit from our Services.

 

  1. Automated decision making & profiling

We do not make any decisions in relation to your Personal Data solely by automated means without any human involvement (i.e. we do not conduct automated decision making). We do not conduct any automated processing of Personal Data to evaluate certain things about you (i.e. we do not conduct profiling).

 

  1. How to complain

In the event you wish to complain about our use of your Personal Data, please send an email with the details of your complaint to info@hoxomedia.com. We will look into and respond to any complaints we receive as soon as reasonably practicable. You also have the right to lodge a complaint with the ICO. We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please seek to contact us in the first instance. For further information on your rights and how to complain to the ICO, please refer to the ICO website: www.ico.org.uk.

 

  1. Contact Details

Full name and details of legal entity: Hoxo Media Limited, a private limited company registered in England and Wales, with company registration number 10657298 and registered office at 7 Bell Yard, London, England, WC2A 2JR;

Email address: info@hoxomedia.com; and
Postal address: Hoxo Media Limited, 7 Bell Yard, London, England, WC2A 2JR.

 

  1. Changes to this Privacy Policy

We keep this Privacy Policy under regular review. Any changes we may make to this Privacy Policy will be posted on the Website and, where we believe that the changes to the Privacy Policy are material, we will notify you by e-mail. Please check back frequently to see any updates or changes to this Privacy Policy.

 

This Privacy Policy was last updated on 31 October 2023.