Privacy Policy

Converted Media Ltd t/a Prospect Path (“Prospect Path”, we“, ” us“ or ” our“) is committed to respecting your privacy. Please read this privacy policy carefully to understand our practices regarding your personal data and how we will treat it.

ABOUT OUR PRIVACY POLICY

This privacy policy applies to your access to and use of:

  • the website prospectpath.com;

  • the web and application called ‘Prospect Path’,

(together the ”Platform“) including all data, services and products available at or through the Platform.

This privacy policy, together with the terms and conditions for use of the Prospect Path web and mobile application (being either those set out here or as otherwise agreed between you and us), sets out the basis on which any personal data we collect from you, or that you provide to us will be processed by us.

By accessing and/or using the Platform, you are accepting and consenting to the practices described in this policy.

In this Policy we will explain:

  • What types of personal information Prospect Path collects and how it is used.

  • How Prospect Path collects your personal information, including whether personal information is collected automatically.

  • How long Prospect Path retains your personal information.

  • How and when Prospect Path shares your personal information with others.

  • How Prospect Path protects your personal information.

  • What choices and rights are available to you regarding the use of your personal information, including how to access and update personal information.

  • How personal information submitted to our Services or collected through our Services is treated.

  • How to update your communication preferences.

  • Whether children under the age of 13 are permitted to use our Services.

**CONTACT INFORMATION

For the purpose of the General Data Protection Regulations (the “ GDPR”), the data controller is Converted Media Ltd whose office is at The Core, Science Central, Bath Lane, Newcastle Upon Tyne, NE4 5TF United Kingdom, ICO Reg. No. xxxxxx.

Questions, comments and requests regarding this privacy policy are welcomed and should be addressed to customerteam@prospectpath.com.

INFORMATION WE MAY COLLECT

We may collect the following information:

1. Information you give us (Client Supplied Data): You may give us information about you by filling in forms on the Platform, for example when you register as a user of the Platform, register your billing details to become a customer, open a support request, post on our blog, take part in competitions, prize draws or surveys, or by corresponding with us by phone, e-mail or otherwise. The information you give us may include your name, e-mail address, employment details, phone number and billing address.

2. Information we may automatically collect about you (Automatic Device Data): With regard to each of your visits to the Platform we may automatically collect the following information:

  • Visit information - including the full URL clickstream to, through and from the Platform (including date and time), page response times, errors, length of visits to certain pages, page interaction information, actions taken within the application and methods used to navigate away from the page;

  • Technical information - including the Internet Protocol address used to connect your device to the Internet, your login information, browser type and version, geographical location, browser plug-in types and versions and operating system.

3. Information from other sources (Other Data): From time to time we may work with third parties (including, for example, business partners, sub-contractors in technical and payment services, intelligence providers and analytics providers) and may receive information about you from them. 

The above types of information may not always contain personal data (i.e. data which identifies a person). Some of this information may instead contain non-personal data (i.e. data that does not identify you). As non-personal data is anonymous, this privacy policy does not restrict or limit our use and disclosure of non-personal data.

USE OF COOKIES

We use cookies in order to provide a better service or identify which pages on the Platform are of special interest. A cookie is a small piece of information which a website stores on your web browser and which can later be retrieved.

We use the following cookies:

  • Strictly necessary cookies. These are cookies that are required for the operation of the Platform. They include, for example, cookies that enable you to log into secure areas of the Platform or our services.

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around the Platform when they are using it. This helps us to improve the way the Platform 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 Platform. This enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region).

  • Targeting cookies. These cookies record your visit to the Platform, the pages you have visited and the links you have followed. We will use this information to make the Platform 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 block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our platform.

Except for essential cookies, all cookies will expire after 1 year.

HOW DO WE USE PERSONAL DATA?

We may process personal data in connection with the following purposes:

Client Supplied Data

  • to provide you with information and services that you request;

  • to bill and collect money owed to us by our Clients;

  • to update our records and generally maintain your account with us;

  • to provide you with special offers, promotions, surveys and other information about services we feel may interest you, where you consent to receiving such information;

  • to notify you about changes to this privacy policy and other terms that you have agreed to;

  • for research and development purposes to evaluate and enhance the Platform; and

  • to deal with your queries, complaints or concerns,

Automatic Device Data

  • to provide our service to you;

  • to present content from the Platform in an effective manner to you;

  • to administer the Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;

  • as part of our efforts to keep the Platform safe and secure;

  • to enforce compliance with our Terms of Service and applicable law;

  • to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you; and

  • to make suggestions and recommendations to you and other users of our site about services that may interest you or them,

Other Data

  • to evaluate our client relationships, or potential client relationships, and the benefit, or potential benefit, obtained from the Platform;

  • we may also combine this information with the above information and use this information for the purposes set out above.

We shall not process personal data for any other purpose, unless such purpose is expressly communicated to you at the point your personal data is being collected.

DIRECT MARKETING - HOW TO UNSUBSCRIBE

If you have consented to receive marketing communications from us via email you can change your mind and withdraw that consent. You can opt-out by clicking on the Unsubscribe link at the bottom of the email you’ve received or updating your user account settings. Alternatively, you can send an email to customerteam@prospectpath.com

LEGAL BASIS

The legal basis for which we act as Data Controller are as follows:

  1. GDPR Article 6(1)(b) - processing of your personal data is necessary for the performance of our contract with you, our customer

  2. GDPR Article 6(1)(c) - processing of your personal data is necessary for compliance with a legal obligation. Specifically, this relates to financial and accountability data

  3. GDPR Article 6(1)(f) - processing of your personal data is necessary for legitimate interests of both Prospect Path and you as our customer. Specifically:

a. Ensuing Prospect Path’s systems are secure and for the purposes of performance and error monitoring and incident response

b. Improving the performance and user experience of the Prospect Path product

WHO PROCESSES YOUR INFORMATION?

We may disclose your personal data to the following persons:

1. Disclosure of information within Prospect Path: We limit access to your personal data to employees who reasonably need to process such information as described under this policy. In this situation we:

  • shall take commercially reasonable steps to ensure the reliability and appropriate training of any Authorized Employee.

  • shall ensure that all Authorized Employees are made aware of the confidential nature of Personal Data.

  • shall take commercially reasonable steps to limit access to Personal Data to only Authorized Individuals.

2. Disclosure of information to particular third parties: We may disclose your personal data to the following third parties:

  • The members of our group (which means our subsidiaries, our parent company and its subsidiaries, as defined in section 1159 of the UK Companies Act 2006) for the purposes outlined in this Privacy Policy

  • To contractors, service providers such as Intercom, and other third-parties we use to support our business. These entities are bound by contractual obligations to keep personal information confidential and can use it only for the purposes for which we disclose the information to them.

Prospect Path shall:

a) notify the Client if it receives any complaint, notice or communication which relates directly to the processing of Personal Data, or to either party’s compliance with Data Protection Laws, and shall fully co-operate and assist the Client in relation to any such complaint, notice, communication or non-compliance; and

b) not engage another processor without prior specific or general written authorisation of the Client and in the case of general written authorisation, inform the Client of any intended changes concerning the addition or replacement of other processors, thereby giving the Client the opportunity to object to such changes

c) before disclosing Personal Data to any processor, enter into a contract with that processor under which the processor agrees to comply with obligations equivalent to those set out in these GDPR Terms; and

d) before disclosing Personal Data to any of its employees and representatives, and the employees and representatives of each of its processors, in each case who have access to the Personal Data, ensure that those persons:

(i) have undergone appropriate training in data protection and the care and handling of Personal Data;

(ii) are bound to hold the information in confidence to at least the same standard as required under this Agreement (whether under a written agreement or otherwise)

3. Disclosure of information in certain circumstances: We may also disclose your personal data:

  • in the event 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 asset;

  • if we or substantially all of our assets are acquired by a third party, in which case personal data held by us about our customers will be one of the transferred assets; or

  • if we are under a duty to disclose or share your personal data in order to comply with any legal obligations, or in order to enforce or apply our terms for use of the Prospect Path web and mobile application and other agreements; or to protect the rights, property or safety of Converted Media Ltd, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Beyond this, we will not share your personal data with any other person without your consent.

LINKS TO OTHER WEBSITES

The Platform may contain links to third party websites. However, we are not and shall not be held responsible for the content of such websites, or their privacy policies. If you visit another website, we advise you to review their privacy policy and other general terms of use.

DO NOT TRACK DISCLOSURE

“Do Not Track” is a standard that is currently under development. Because it is not yet finalised, Prospect Path adheres to the standards in this policy and does not monitor or follow any Do Not Track browser requests. That said, some of our features may have the ability to monitor or follow Do Not Track browser requests.

RIGHT OF ACCESS & RECTIFICATION

The GDPR gives you the right to access and request a correction of personal data held about you. Your right of access can be exercised in accordance with the GDPR. 

You have the right to access and correct your personal information. If you want to review or correct your personal information, you can login to the application and visit your account profile page, typically designated as “My Account”, or contact us at customerteam@prospectpath.com

RIGHT TO DELETE PERSONAL DATA

You have the right to request deletion of personal information we hold about you and we have the obligation to erase your personal information, where:

  • the personal information is no longer necessary in relation to the purposes for which it was collected or otherwise processed,

  • you withdraw consent on which the processing is based and where there is no other legal ground for the processing,

  • you object to the processing and there are no overriding legitimate grounds for the processing,

  • the personal information has been unlawfully processed, or

  • the personal information has to be erased for compliance with a legal obligation in the European Union or a Member State law to which Prospect Path is subject.

If you want to request removal of your personal information from our Websites or Services, you can login to the application or you may send us an email at the address noted in the Contact Information section above. You can also request closure of your account. We will respond to your request within 30 days.

In some cases, we may not be able to remove your personal information, in which case we will let you know that we are unable to do so and why.

RIGHT TO DATA PORTABILITY

You have the right to receive or transfer a copy of your personal information, where:

  • we are relying upon your consent or the fact that the processing is necessary for the performance of a contract to which you are party as the legal basis for the processing, and

  • personal information is processed by automatic means.

This copy will be provided to you in a common machine-readable format. You may also require us to transmit it to another party where this is technically feasible.

If you want to request a copy of your personal information, you can contact us via the email address noted in the Contact Information section above.

RIGHT TO RESTRICT PERSONAL INFORMATION PROCESSING

You have the right to request the restriction of processing of your personal information, where:

  • you contest the accuracy of the personal information until we take sufficient steps to correct or verify its accuracy,

  • where the processing is unlawful but you do not want us to erase the personal information,

  • where we no longer need the personal information for the purposes of the processing, but you require the information for the establishment, exercise or defence of legal claims, or

  • where you have objected to processing justified on legitimate interest grounds (see below) pending verification as to whether Prospect Path has compelling legitimate grounds to continue processing.

Where personal information is subjected to restriction in this way we will only process it with your consent or for the establishment, exercise, or defence of legal claims. This right includes restricting the processing of your personal information to only include storage of your personal information (e.g. during the time when Prospect Path assesses whether you are entitled to have personal information erased).

If you want to request restriction of processing of your personal information, you can contact us via the email address noted in the Contact Information section above.

RIGHT TO OBJECT TO PROCESSING JUSTIFIED ON LEGITIMATE INTEREST GROUNDS

Where we are relying upon legitimate interest to process personal information, you have the right to object to that processing. If you object, we must stop that processing unless we can either demonstrate compelling legitimate grounds for the processing that override your interests, rights and freedoms or where we need to process the personal information for the establishment, exercise, or defence of legal claims. Where we rely upon legitimate interest as a basis for processing we believe that we can demonstrate such compelling legitimate grounds, but we will consider each case on an individual basis.

If you want to object to the processing of your personal information, you can contact us via the email address noted in the Contact Information section above.

RIGHT TO BE INFORMED OF THE APPROPRIATE SAFEGUARDS WHERE PERSONAL INFORMATION ARE TRANSFERRED TO A THIRD COUNTRY OR TO AN INTERNATIONAL ORGANIZATION

Refer to the Terms of Service and this Privacy Policy for information on the safeguards that have been put in place to protect your personal information for transfer outside of the European Economic Area. For transfers to countries without an adequacy decision by the European Commission, Prospect Path puts appropriate safeguards through contractual obligations.

RIGHT TO WITHDRAW CONSENT

Where you have provided us with your consent to process personal information, you have the right to withdraw such consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can do this by:

  • using certain web browser and opt-out options discussed in this Privacy Policy to limit the personal information you provide to us or our third-party partners

  • send us an email at the address noted in the Contact Information section above,

  • following the unsubscribe instructions included in emails,

RIGHT TO SUBMIT COMPLAINTS OR REPORT ABUSE

You also have the right to lodge a complaint with a supervisory authority, in particular in your country of residence, if you consider that the processing of your personal information infringes applicable laws.

If you need to report abuse, you can contact us via the email address noted in the Contact Information section above.

CHILDREN UNDER THE AGE OF 13

Our Websites and Services are not intended for children under 13 years old.

We do not knowingly collect personal information from children under 13 years old. If you are under 13 years old, do not use or provide any information on our Websites or Services including on or through any of their features, register on the Websites or Services, make any purchases through the Websites or Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 years old, we will delete that information without undue delay.

If you believe we might have any information from or about a child under 13 years old, please contact us using the information in the “Contact Information” section above.

COMPLIANCE

Prospect Path will, upon the Client’s reasonable written request, provide all information necessary to demonstrate compliance with these GDPR Terms, and allow the Client or an auditor appointed by the Client to carry out audits, including inspections of facilities, equipment, documents and electronic data, relating to the processing of Personal Data by Prospect Path or any processor, to verify compliance with these GDPR Terms.


California Privacy Rights 


California law requires us to provide California residents with additional information regarding how we collect, use, and share your "personal information" (as defined in the California Consumer Privacy Act ("CCPA")). 


Subject to certain limitations, the CCPA provides you the right to request:
- That we provide you access to details on the categories or specific pieces of personal information we collect and/or sell (including how we use and disclose this information, to whom we may sell it);
- The categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information
- That we delete any or all of your personal information;
- To opt out of any “sale” or disclosure of your personal information that may occur; and
- To not be discriminated against for exercising any of the above rights. 


Categories of personal information we collect. Throughout this Policy, we discuss in detail the specific pieces of information we collect from and about users. Below are the categories of personal information we collect: 


- Identifiers (such as name and title, contact details, and company name);
- Internet or other network or device activity (such as browsing history or app usage);
- Inference data about you; and
- Other information that identifies or can be reasonably associated with you. 


To request to exercise your California privacy rights under the CCPA please click here and complete the form.

If you would like to opt out of the sale of your personal information please click here and complete the CCPA opt out form. 


Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.   


We will verify your request using information associated with your account, including your email address. Further identification may be required. You may also designate an authorized agent to act on your behalf. 


Nevada Privacy Policy 


Nevada law requires us to provide certain Nevada consumers the ability to opt out of the “sale” of “personally identifiable information” as such terms are defined under Nevada law. We do not engage in such activity; however you may submit a request to opt out of any potential future sales under Nevada law by emailing customerteam@convertedmedia.com.

CHANGES TO OUR PRIVACY POLICY

Any changes to the privacy policy will be posted here.

If we want to make material changes to the way we use your personal data, we will ask for your consent before we do so.

Updated December 2019

The Core, Science Central, Bath Lane, Newcastle upon Tyne, NE4 5TF, UK

© 2020 Converted Media Ltd