Privacy Policy

This privacy policy statement outlines the collection and processing of personal data through the use of sites owned by Brandium, Inc. Ltd., including EditorialMarketing.com, Brandingmag.com, Branding.news, RebelsRulers.com, BrandingOverTea.com, and BrandingNite.com, hereafter referred to as “Our Sites” or “Our Properties.” The term “we’’ in this policy refers to Our Sites. It is important that you carefully read and understand this policy, as it explains how we collect, use, and protect your personal data in accordance with applicable laws and regulations.

By providing us with your data, you warrant:

You have read, understood, and agreed to this privacy policy; and
You are over 13 years of age.

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.

Personal data controller

Brandium, Inc. Ltd., a company registered in England and Wales, registration number 10061843, with a registered postal address at WOKING, SURREY, 102 Railway House, 14 Chertsey Road, GU21 5AH, U.K., will be the controller of your personal data.

If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact us using the details set out below.

Contact details

Our full details are:
Full name of legal entity: Brandium, Inc. Ltd.
Email address: hello[at]editorialmarketing[dot]com
Postal address: WOKING, SURREY, 102 Railway House, 14 Chertsey Road, GU21 5AH, U.K.

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance at hello[at]editorialmarketing[dot]com with the subject line [Personal data issue].

Do we collect personal data?

In accordance with your use of Our Sites, we may collect certain personal data, which may include, but is not limited to: your name, gender, business or company name and details, job title, contact information (such as email addresses and telephone numbers), demographic information (such as location, preferences, and interests), financial information (such as credit/debit card numbers), IP address, web browser type and version, and operating system.

Should you choose to register on Our Sites using your Facebook, Twitter, LinkedIn, Google, or other third-party service account, we will only receive the necessary data required for registration (such as your name, surname, email address, company name, and job title).

We do not collect any Sensitive Data about you. Sensitive Data pertains to data that may include 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. Additionally, we do not collect any information about criminal convictions and offenses.

How do we collect personal data?

We collect data about you through various means, including:

I. Directly from you when you provide information by filling in forms, making a purchase, or creating an account on Our Sites or by sending us direct emails.
II. Through cookies and similar technologies when you use Our Sites, once you have agreed to them or failed to disagree.
III. From third parties such as analytics providers (e.g., Google) based inside or outside the EU, advertising networks (e.g., Facebook) based inside or outside the EU, search information providers (e.g., Google) based inside or outside the EU, and providers of technical, payment, and delivery services (e.g., data brokers or aggregators).
IV. From publicly available sources.
V. From social media platforms, such as Facebook, Twitter, and LinkedIn, when you interact with our social media accounts or share our content.
VI.From other users of Our Sites, such as when they mention or tag you in their content.

It is important to note that we collect data in accordance with the General Data Protection Regulation (GDPR) and all other applicable laws and regulations.

Legal basis for processing

We process your personal data for various reasons, and in order to do so lawfully, we rely on certain authorized requirements. These include:

I. Your consent: We may ask for your explicit consent to process your personal data in certain circumstances, such as when we want to send you marketing communications or when you use Our Sites and agree to the use of cookies.
II. Contractual obligations: When you enter into a contract with us, we may need to process your personal data in order to fulfill our obligations under that contract. For example, if you purchase a product/service from us, we will need to process your personal data to fulfill your order and deliver the product or service to you.
III. Legitimate interests: We may also process your personal data when it is in our legitimate interests to do so, provided that such interests are not overridden by your rights and interests. For example, we may process your personal data for marketing purposes, to monitor and improve Our Sites, or to prevent fraud or security breaches.
IV. Legal obligations: Finally, we may also process your personal data when we are required to do so by law, such as when we are compelled to disclose your personal data to law enforcement or regulatory authorities.

It’s important to note that we will only process your personal data for the specific purposes for which it was collected, and we will take appropriate measures to ensure that your personal data is kept accurate, up-to-date, and secure at all times.

Change of purpose

As stated above, 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.

What about children’s data?

Our Sites are not designed or directed towards individuals under the age of 13, and we do not knowingly collect or process personal information related to individuals under the age of 13. If you believe that we have collected personal information from a child under the age of 13, please contact us at hello[at]editorialmarketing[dot]com with the subject [Child Data] so that we can delete the information as soon as possible.

Why do we need your personal data?

We only ask for and use the necessary data to ensure the following points:

Offering a customized web experience, with ads that are relevant to you;
Improving Our Sites based on how you and our other visitors interact with them, to offer you a seamless and ever-improved experience;
Offering you access to our free and/or paid content;
Sending you our newsletter (if you have subscribed to it) containing premium insights and other relevant information;
Sending you information or content which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
Promote use of our services to you and share promotional and information content with you in accordance with your communication preferences.

For how long do we store your personal data?

We will store your personal data for as long as it is reasonably necessary for achieving the purposes set forth in this Privacy Policy (including providing Our Sites to you), which includes (but is not limited to) the period during which you have an account with any of Our Sites. We will also retain and use your personal data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you wish to receive a copy of the personal data that you have agreed to share with us, then please email us at hello[at]editorialmarketing[dot]com with the subject [My Personal Data].

If you wish to remove your consent and have your data deleted (meaning you will not receive any future insights and might stop benefitting from your subscription if you request that your account be deleted), then please email us at hello[at]editorialmarketing[dot]com with the subject [Consent Removal].

How do we protect your personal data?

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorized 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.

Who do we share your information with?

As stated above, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know such data. These third parties include:

Service providers who provide IT and system administration services
Professional advisers including lawyers, bankers, auditors, and insurers
Government bodies that require us to report processing activities
Third parties such as copywriters, customer support, and virtual assistants
Third parties to whom we sell, transfer, or merge parts of our business or our assets.

What are your rights?

Under certain circumstances, you have rights under data protection laws in relation to your personal data. These rights are as stipulated below:

I.Rights to be informed.
You have the right to be provided with clear, transparent, and easily understandable information about how we use your personal data and your rights. This is why we are providing you with the information in this Privacy Policy.

II. Right of access.
You have the right to obtain access to your personal data (if we are processing it) and certain other information (similar to that provided in this Privacy Policy). This is so you are aware and can check that we are using your personal data in accordance with data protection law.

III. Right to rectification.
You are entitled to have your personal data corrected if it is inaccurate or incomplete.

IV. Right to erasure.
This is also known as ‘the right to be forgotten’ and, in simple terms, enables you to request the deletion or removal of your personal data where there is no compelling reason for us to keep using it. This is not a general right to erasure; there are exceptions.

V. Right to restrict processing.
You have the right to ‘block’ or suppress further use of your personal data in certain circumstances. When processing is restricted, we can still store your personal data, but may not use it further.

VI. Right of data portability.
You have the right to obtain and reuse your personal data in a structured, commonly used, and machine-readable format in certain circumstances. In addition, where certain conditions apply, you have the right to have such information transferred directly to a third party.

VII. Right to object to processing.
You have the right to object to us processing your personal data for our legitimate business interests or for direct marketing purposes (including in each case any related profiling).

VIII. Right to withdraw consent to processing.
If you have given your consent to us to process your personal data for a particular purpose (for example, direct marketing), you have the right to withdraw your consent at any time (although if you do so, it does not mean that any processing of your personal data up to that point is unlawful).

IX. Right to make a complaint to the data protection authorities.
You have the right to make a complaint to the Information Commissioner’s Office (ICO) if you are unhappy with how we have handled your personal data or believe our processing of your personal data does not comply with data protection law.

Changes to your personal data

It is important to us that the personal data we hold about you is accurate and current. We will take reasonable steps to ensure that the personal data we collect, use, and disclose is accurate, complete, and up-to-date. However, we rely on you to inform us if your personal data changes during your relationship with us.

If you have an account with us, you can update your personal data by logging in to your account and making the necessary changes. If you do not have an account with us, or if you require assistance with updating your personal data, please contact us using the contact information provided in this policy.

We will update or correct your personal data as soon as reasonably practicable, and in any event, within 30 days after receiving your request, unless we are prevented from doing so by applicable laws or regulations. Please note that we may need to retain certain personal data for record-keeping purposes, to complete transactions, or to comply with our legal obligations.

What is our Cookies Policy?

Kindly refer to our Cookies Policy.

How do we deal with third-party links?

Occasionally, at our discretion, we may include or offer third-party products or services on Our Sites. These third-party properties have separate and independent privacy policies; therefore, we have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of Our Sites and welcome any feedback about the third-party properties we associate with.

How do we deal with third-party links?

Do we transfer your data internationally?

Some of our external third parties are based or send personal data 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 outside 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:

I. Where we use certain service providers, 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.

II. 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 Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data outside of the EEA.

Privacy notice for California residents

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies to individuals who reside in the State of California (“consumers” or “you”). We adopt this notice along with the Privacy Policy to comply with the California Consumer Privacy Act of 2018, as amended (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Information we collect

We have collected the following categories of Personal Information (PI) from consumers within the last twelve (12) months:

Category	Examples
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number (from employees—see B), or other similar identifiers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Personal Information does not include publicly available information that is lawfully made available to the general public from federal, state, or local government records. Note: Some personal information included in this category may overlap with other categories.
C. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
D. Internet or other electronic network activity.	Browsing history, search history, information on a consumer’s interaction with an internet website, application, or advertisement.
E. Geolocation data.	Physical location or movements.
F. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information. This may include but is not limited to customer-submitted photographs, videos, and audio.
G. Professional or employment-related information.	Current or past job history or performance evaluations.
H. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
I. Inferences drawn from other personal information to create a profile about a consumer.	Profile reflecting a consumer’s preferences, behavior.

We obtain the categories of Personal Information listed above from the following categories of sources:

Directly from you. For example, from forms you complete on our website.
Indirectly from you. For example, from observing your actions on our website or interactions with our advertisers.
From third parties such as third parties you use to log in to our Services.

The chart above reflects the categories of PI required by the CCPA. There may be additional information that we collect that meets the CCPA’s definition of PI but is not reflected by a category, in which case we will treat it as PI as required by the CCPA but will not include it when we are required to describe our practices by category of PI.

As permitted by applicable law, we do not treat deidentified data or aggregate consumer information as PI and we reserve the right to convert, or permit others to convert, your PI into deidentified data or aggregate consumer information, and may elect not to treat publicly available information as PI. We have no obligation to re-identify information or keep it longer than we need it to respond to your requests.

Disclosures of Personal Information for a business purpose

We may disclose your Personal Information to a service provider or a third party for a business purpose. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information in our role as a business for a business purpose:

Category A: Identifiers
Category B: Personal information categories in Cal. Customer Records statute
Category C: Commercial information
Category D: Internet information
Category E: Geolocation
Category F: Sensory data
Category G: Professional or employment-related information
Category H: Non-public education information
Category I: Inferences

We may disclose your Personal Information for a business purpose to the following categories of third parties:

Our affiliates
Service providers
Advertising networks, internet service providers, data analytics providers, government entities, operation systems and platforms, social networks and consumer data resellers.
Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

Sales of Personal Information

We do not sell any Identifiers or Personal Information. In the preceding twelve (12) months, what we have sold is limited to:

Category D: Internet information
Category E: Geolocation
Category G: Professional or employment-related information
Category I: Inferences

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to specific information and data portability rights

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of Personal Information we collected about you.
The categories of sources from which the Personal Information is collected about you.
Our business or commercial purpose for collecting that Personal Information.
The categories of third parties with whom we share that Personal Information.
The specific pieces of Personal Information we collected about you (also called a data portability request).
If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion request rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents; protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the rights of other consumers to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the business’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising access, data portability, and deletion rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing hello[at]editorialmarketing[dot]com. 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. You may also make a verifiable consumer request on behalf of your minor child (12 and under).

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or your authority to make the request and confirm the Personal Information relates to you. In some instances, if we cannot verify your identity to provide you access to personal information, you may choose to delete such personal information.

We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We also reserve the right to reject your request to access or update your personal information for a number of reasons including, for example, if the request risks the privacy of other users or is unlawful.

Response timing and format

Where possible, we will respond to a verifiable consumer request within forty-five (45) days of its receipt; however, if we require more time, we will inform you of the reason and extension period.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information sales opt-out and opt-in rights (“Do Not Sell My Info”)

You have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by emailing hello[at]editorialmarketing[dot]com.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize Personal Information sales. However, you may change your mind and opt back in to Personal Information sales at any time by emailing us at hello[at]editorialmarketing[dot]com.

We will only use Personal Information provided in an opt-out request to review and comply with the request.

Non-discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer, will reasonably relate to your Personal Information’s value to us and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Authorized representative

You may designate an authorized agent to make a request under the CCPA on the consumer’s behalf by emailing us from the email address associated with your account, indicating: your name, the fact that you would like to indicate an authorized agent, the name of your authorized agent, and the email address of your authorized agent.