Screen Plus Limited’s Privacy Statement
This document declares the undertakings by Screen Plus Limited in relation to its handling of Your Data.
Contents

• Data Collection
• Data Security
• Data Use
• Data Disclosure
• Data Retention and Destruction
• Access by You to Your Personal Data
• Information about Data Handling Practices
• Handling of Enquiries, General Concerns and Complaints
• Enforcement
• Changes to These Privacy Undertakings
• Definitions

Data Collection
Screen Plus Limited undertakes to collect Your Data by means that are:

• fair;
• legal; and
• transparent.

If you visit Screen Plus Limited’s web-site, your web-browser automatically discloses, and Screen Plus Limited’s web-server automatically logs, the following information: the date and time, the IP address from which you issued the request, the type of browser and operating system you are using, the URL of any page that referred you to the page, the URL you requested, and whether your request was successful. This data may or may not be sufficient to identify you.
Any additional data that you provide, e.g. in a web-form, may also be logged. This data may or may not be sufficient to identify you.
Any additional data that your web-browser automatically provides may also be logged. This will be the case, for example, if your browser has previously been requested to store data on your computer in 'cookies' and submits them each time you request a web-page within a particular domain (such as screenplus.co.uk). This data may or may not be sufficient to identify you.
If you disclose personal data to Screen Plus Limited in conjunction with an identifier such as your name or your credit-card details, Screen Plus Limited will collect Your Data. Moreover, any data that becomes available to Screen Plus Limited through any of the means described in the preceding paragraphs may be able to be associated with that identifier, and hence become Your Data.
Subject to the qualifications immediately below, Screen Plus Limited undertakes to collect Your Data from you and not from other parties. This undertaking is qualified as follows:

• where Screen Plus Limited reasonably considers that the protection of its financial interests requires that it gather YourData from other sources, or from additional sources. This applies in particular where Screen Plus Limited has a lending exposure to you, and seeks information about your creditworthiness;
• where Screen Plus Limited reasonably considers that its capability to deliver quality services to you will be materially enhanced by gathering YourData from other sources. This applies in particular to consumer profile data.

Where Screen Plus Limited collects Your Data from sources other than you, it undertakes:

• to do so only by legal means;
• to do so only with your Consent; and
• to declare to you what sources it uses, and under what circumstances.

Screen Plus Limited undertakes to declare the purpose of collection in a manner which is clear and meaningful, and to avoid vague, highly inclusive statements such as 'to support our operations'.
Data Security
Screen Plus Limited undertakes to store Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Screen Plus Limited undertakes to store Your Data only in jurisdictions where data protections are at least equivalent to those required under the OECD Guidelines.
Screen Plus Limited undertakes to transmit Your Data in a manner that ensures security against unauthorised access, alteration or deletion, at a level commensurate with its sensitivity.
Screen Plus Limited undertakes to implement appropriate measures to ensure security of Your Data against inappropriate behaviour by Screen Plus Limited’s staff-members and contractors. These include:

• training for staff in relation to privacy;
• access control, to limit access to Your Data to those staff and contractors who have legitimate reasons to access it;
• particularly in the case of sensitive data, audit trails of accesses, including the identities of staff and contractors accessing the data;
• reminders to staff and contractors from time to time about the importance of data privacy, and the consequences of inappropriate behaviour;
• declaration of appropriately strong sanctions that are to be applied in the event of inappropriate behaviour
• clear communication of policies and sanctions; and
• processes to audit, to investigate and to impose sanctions.

Data Use
Use refers to the application of Your Data by any part of Screen Plus Limited, or any staff-member or contractor of Screen Plus Limited in the course of their work. Screen Plus Limited undertakes to use Your Data only for:

• the purposes for which it was collected;
• such other purposes as are subsequently agreed between Screen Plus Limited and You;
• such additional purposes as may be required by law. In these circumstances, Screen Plus Limited will take any reasonable steps available to it to communicate to You that the use has occurred, unless it is precluded from doing so by law; and
• such additional purposes as are authorised by law (in particular to protect Screen Plus Limited’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Screen Plus Limited or have committed a breach of the criminal law).

Screen Plus Limited undertakes to use YourData only if it has demonstrable relevance to the particular use to which it is being put.
Screen Plus Limited undertakes to use YourData in such a manner as to take into account the possibility that it is not of sufficient quality for the purpose, e.g. because it is inaccurate, out-of-date, incomplete, or out-of-context.
Profile: Screen Plus Limited and its associated sites collects profile information supplied by users who register. The supplied data allows us to customise our content and deliver specific items of interest to our users and also assists our advertisers to better understand their target audience.
Subscriber Data: We use Subscriber Data to deliver email newsletters and product alerts on topics of interest to Subscribers who have signed up for those services. We may also send general promotional and marketing materials to Subscribers. We use Subscriber Information to understand our customer base and to market our services to our customers.
Third Party Personal Information: We use third party email addresses provided for the ‘email an article’ option only for the purpose of sending the specific article being viewed to a subscriber-specified third party and for no other purpose.
Sharing Information: Screen Plus Limited may share profile information collected as follows:

• Except as set forth herein, your contact information (name, email address and country) will not be shared with anyone other than Screen Plus Limited and the suppliers/advertisers whose information you have viewed (including, but not limited to, email address; or product information, including, but not limited to, specifications, product announcements)
• We may send general promotional and marketing materials to our users, including marketing research surveys. We also use profile information to understand our customer base and to market our services to our customers.
• Profile information collected when you register or log in on Screen Plus’s associated sites available only to Screen Plus Limited. Strategic partners provide some of the services offered on Screen Plus Limited.
• Screen Plus Limited email communications are only accessible by designated recipients, except that Screen Plus Limited staff or authorised contractors involved in management and maintenance may have access to email communications.
• You may have your personal information removed from the system by contacting webmaster@screenplus.co.uk

Data Disclosure
Disclosure refers to making YourData available to any party other than Screen Plus Limited and You. The term disclosure may include many different conditions of data transfer, including selling, renting, trading, sharing and giving.
Screen Plus Limited undertakes to disclose Your Data only under the following circumstances:

• in the course of business being conducted between You and Screen Plus Limited, where disclosure is necessary to a contractor, such as a transport company. Where Your Data is disclosed in this way, Screen Plus Limited undertakes to exercise control over Screen Plus Limited’s contractors to ensure that their actions are compliant with these Terms;
• in other circumstances that are directly implied by the purpose agreed between You and Screen Plus Limited at the time of data collection or subsequently. Where Your Data is disclosed in this way, Screen Plus Limited undertakes to exercise control over Screen Plus Limited’s contractors to ensure that their actions are compliant with these Terms;
• with your consent, or at your request;
• where required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena. In these circumstances, Screen Plus Limited will take any reasonable steps available to it to communicate to You that the disclosure has occurred, unless it is precluded from doing so by law;
• where permitted by law (e.g. the reporting of suspected breach of the criminal law to a law enforcement agency; and in an emergency, where Screen Plus Limited believes on reasonable grounds that the disclosure of YourData will materially assist in the protection of the life of health of some person), provided that Screen Plus Limited will apply due diligence to ensure that the exercise of the permission is justifiable.

In all cases, Screen Plus Limited undertakes to disclose only such of Your Data as is necessary in the particular circumstances.

Data Retention and Destruction
Subject to the qualifications immediately below, Screen Plus Limited undertakes:

• to retain Your Data only as long as is consistent with its purpose; and
• to destroy Your Data when its purpose has expired, and to do so in such a manner that Your Data is not subsequently capable of being recovered.

This undertaking is qualified as follows:

• Your Data may be retained in Screen Plus Limited’s logs, backups and audit trails within short-term retention cycles that are devised to protect the company's operations. In such cases, Your Data will be destroyed in accordance with those cycles;
• Your Data may be retained beyond the expiry of its purpose if that is required by law, such as a provision of a statute, or a court order such as a search warrant or subpoena, or a warning by a law enforcement agency that delivery of a court order is imminent. In these circumstances, Screen Plus Limited:
• will take any reasonable steps available to it to communicate to You that Your Data is being retained, unless it is precluded from doing so by law; and
• will only retain Your Data while that provision is current, and will then destroy Your Data;
• Your Data may be retained beyond the expiry of its purpose if it is authorised by law (in particular to protect Screen Plus Limited’s interests, e.g. if it believes on reasonable grounds that You have failed to fulfil your undertakings to Screen Plus Limited or have committed a breach of the criminal law). In these circumstances, Screen Plus Limited will only retain Your Data while that situation is current, and will then destroy Your Data.

Access by You to Your Personal Data
Screen Plus Limited undertakes to provide you with access to Your Data, subject to only such conditions and processes as are reasonable in the circumstances. In particular, Screen Plus Limited undertakes to enable access:

• conveniently;
• without unreasonable delay; and
• without cost.

Screen Plus Limited undertakes to establish and operate identity authentication protections for access to Your Data that are appropriate to its sensitivity, but practical. This may involve some inconvenience; for example, relatively straightforward procedures may be involved in order to provide you with access through a channel that you have previously registered with Screen Plus Limited (such as a particular email-address), but may impose more onerous procedures if you wish to use some other channel.
In the event that you dispute some aspect of Your Data, Screen Plus Limited undertakes to take reasonable steps in relation to the amendment, supplementation or deletion of Your Data.
You undertake:

• not to seek access for frivolous purposes, or unreasonably frequently;
• to accept that deletion of some data may not be consistent with the provision of particular services by Screen Plus Limited to you.

Information about Data-Handling Practices
Screen Plus Limited undertakes to make information available to you about the manner in which Screen Plus Limited handles your data:

• in general terms, in a readily accessible manner; and
• in more specific terms, on request.

Where Your Data is disclosed to a contractor, Screen Plus Limited undertakes to make information available to you on request about the manner in which Screen Plus Limited’s contractors handle your data.
Screen Plus Limited undertakes to ensure that the information provided is meaningful, and addresses your concerns.
You undertake:

• not to seek such information for frivolous purposes, or unreasonably frequently; and
• to accept that the disclosure of excessive detail may harm the security of Your Data and Screen Plus Limited’s business processes, and may harm Screen Plus Limited’s commercial interests.

Handling of Enquiries, General Concerns and Complaints
If you have enquiries, general concerns, or complaints about these Terms, or about Screen Plus Limited’s behaviour in relation to these Terms, you undertake:

• to communicate them in the first instance:
• to Screen Plus Limited only;
• in sufficient detail;
• through a channel made available by Screen Plus Limited for that purpose;

Screen Plus Limited undertakes:

• to provide one or more channels for communications to Screen Plus Limited, which are convenient to users;
• to promptly provide acknowledgement of the receipt of communications, including the provision of a copy of the communication, the date and time it was registered, and Screen Plus Limited’s reference-code for the communication;
• to promptly provide a response to the communication, in an appropriate and meaningful manner.

You further undertake to not pursue Screen Plus Limited through any Regulator or the media:

• until and unless Screen Plus Limited has had a reasonable opportunity to respond to the initial communication; and
• while Screen Plus Limited and you remain are conducting a meaningful dialogue about the matter.

Enforcement
Screen Plus Limited declares that its undertakings in these Terms are intended to create legal obligations, and that those obligations are intended to be enforceable under the Laws of England and Wales. Each party irrevocably agrees to submit to the sole jurisdiction of the courts of England and Wales over any claim or matter arising under or in connection with these terms.
Changes to These Privacy Undertakings
Screen Plus Limited undertakes:

• not to materially change these Terms in a manner that reduces the protections for Your Data;
• to take all possible steps to prevent any company that acquires this company or any of its relevant assets from materially changing the Terms applicable to Your Data in a manner that reduces the protections for Your Data;
• where it is considering making changes to these Terms, or creating more specific Terms relating to specific services, to consult with appropriate representative and advocacy organisations;
• where it makes changes to these Terms, to ensure that the differences between successive versions are readily accessible;
• to maintain all prior versions of these Terms in such a manner that they are dated, and readily accessible.

Definitions
Screen Plus Limited means Screen Plus Limited, Unit 5, Millbrook Business Park, Crowborough, East Sussex, TN6 3JZ.
Registered in England. Company Number: 2186183
Your Data means data that is capable of being associated with you, whether or not it includes an explicit identifier such as your name or customer number. In particular, it encompasses all data that Screen Plus Limited is capable of correlating with you, using such means as server-logs and cookie-contents.
Your Data does not refer to data that can no longer be associated with you. This includes aggregated data that does not and cannot identify the individuals whose data are included in the aggregation. Consent means your concurrence with an action to be taken by Screen Plus Limited. Consent may be express or implicit, but in either case must be informed and freely-given.