We are Focus Media Solutions Limited, a company is registered in England (company number 08739817) and whose registered office is at 2nd Floor Regis House, 45 King William Street, London, United Kingdom, EC4R 9AN. Our VAT number is GB181913892 (collectively referred to as “we”, “us” or “our” in this Privacy Notice).
We host and manage www.theastonmartinmagazine.com (“Aston Martin Website”) on behalf of Aston Martin Lagonda Limited (Aston Martin). On behalf of Aston Martin, we produce, and handle subscriptions for, the Aston Martin Magazine.
Purpose of this privacy notice
We respect your privacy and are committed to protecting your personal data.
This privacy notice aims to give you information on how we collect, process, and look after your personal data when you visit the Aston Martin Website (regardless of where you visit it from), including any data you may provide through the Aston Martin Website when you subscribe to receive the Aston Martin Magazine. This privacy notice also tells you about your privacy rights and how the law protects you.
The Aston Martin Website is not intended for children and we do not knowingly collect data relating to children.
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 other notices and is not intended to override them.
We are the controller and responsible for your personal data.
Our data privacy officer (“DPO”) is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights, please contact the DPO using the details set out below.
If you have any questions about this privacy notice or our privacy practices, please contact our DPO in the following ways:
Should you have any concerns, we would appreciate the chance to deal with them in the first instance. If you would like to speak to us in relation to any concerns you have, please contact us by email at [INSERT].
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).
Changes to the privacy notice and your duty to inform us of changes
We keep our privacy notice under regular review. We may amend and update this policy from time to time. Any changes in the future will be posted on this page. This version was last updated on 3 April 2023.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
The Aston Martin Website may include 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 statements. When you leave the Aston Martin Website, we encourage you to read the privacy notice of every website you visit.
2. The data we collect about you
Personal data, or personal information, 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 that you give us through your use of the Aston Martin Website, or by using our applications, corresponding with us by phone, e-mail, or otherwise which we have grouped together as follows:
We 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. 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 personal 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 notice.
Special Categories of Personal Data
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.
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 data when requested, we may not be able to perform the contract we have or are trying to enter into with you for example, we may be unable to process your subscription for the Aston Martin Magazine, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
4. How we use your personal data
When will be use your personal data?
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to 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. Please see the paragraph and table below for the specific purpose for which we use your data.
Purposes for which we will use your personal data
We have set out below, in a table format, 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 (please see paragraph 10 (Glossary) for a definition of legitimate interest).
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your 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.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a new subscriber||(a) Identity|
|Performance of a contract with you (please see paragraph 10 (Glossary) for a definition|
of performance of a contract)
|To process and provide your subscription to Aston Martin Magazine:|
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
(e) Marketing and Communications
|(a) Performance of a contract with you|
(b) Necessary for our legitimate interests (to recover debts due to us)
|To manage our relationship with you which will include:|
(a) Notifying you about changes to our terms or privacy notice
(b) Asking you to leave a review, feedback or take a survey
(d) Marketing and Communications
|(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 administer and protect our business and the Aston Martin Website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||(a) Identity|
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise) (b) Necessary to comply with a legal obligation (please see paragraph 10 (Glossary) for a definition of comply with a legal or regulatory obligation)|
|To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||(a) Identity|
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how customers use the products sold on the Aston Martin Website, to develop them, to grow our business and to inform our marketing strategy)|
|To use data analytics to improve the Aston Martin Website, products/services, marketing, customer relationships and experiences||(a) Technical|
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep the Aston Martin Website updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about goods or services that may be of interest to you||(a) Identity|
|Necessary for our legitimate interests (to develop our products/services and grow our business)|
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 Profile 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 and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or subscribed to the Aston Martin Magazine, in each case, you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside the Focus Media Solutions Limited group of companies for marketing purposes.
This includes direct marketing from Aston Martin in relation to Aston Martin products, services, merchandise, and accessories, promotions, and news. Aston Martin will use your personal data in accordance with its Privacy Notice which is available at [insert link to AM policy on AM website].
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product purchase, warranty registration, product experience or other transactions.
Change of purpose
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.
5.Disclosures of your personal data
We may have to share your personal data with the parties set out below for the purposes set out in the table in paragraph 4 above.
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.
6. International transfers
We share your personal data with other members of the Focus Media Solutions Limited group and between countries in which we operate. This will involve transferring your data outside the UK and European Economic Area (EEA). We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data.
Many of our external third parties are based outside of the UK so their processing of your personal data will involve a transfer outside the UK.
Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring that at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. 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.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. We may retain your personal data for a longer period in the event of a complaint.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
Details of retention periods for different aspects of your personal data are available in our retention policy which you can requested from us by contacting us. Specifically, if you have registered to receive communications from us as part of our mailing list, then we will keep your personal data for up to 6 years, at which time we will seek to obtain consent from you to continue storing your data and contacting you.
9. Your legal rights
Your legal rights in detail
Under certain circumstances, you have rights under data protection laws in relation to your personal data. Please see the table below to find out more about these rights.
|Correction of information||If you notify us that the personal data we hold is complete or inaccurate we will correct or complete the information as soon as possible.|
|Deletion of information||You have the right to request that your personal data be deleted; including if we no longer need it for the purpose we collected it, or, where our legal basis for processing is that you have given consent, you withdraw your consent. Following such a request we will erase your personal data without undue delay unless continued retention is necessary and permitted by law. If we made the personal data public, we will take reasonable steps to inform other data controllers processing about your erasure request.|
|Object to processing||You have the right to object to us processing 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.|
|Restriction on processing||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.You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.|
|Access to information||You have the right to receive a copy of the personal data we hold about you and to check that we are lawfully processing it. Any access request will usually be free of charge. We will endeavour to provide information in a format requested, but we may charge you a reasonable fee for additional (duplicate) copies.|
|Data Portability||You have the right to receive a copy of your personal data which you gave to us. The copy will be provided in a commonly used and machine-readable format. You can also have it transmitted directly from us to another data controller, where reasonably technically possible.|
|Withdraw consent||You may withdraw your 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. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.|
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
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.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Lawful basis Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
Comply with a legal or regulatory obligation means processing your personal data where it is necessary for compliance with a legal or regulatory obligation that we are subject to.