Privacy and Cookies PolicyTelum Media Group PTE Ltd (“Telum”, "we", "us" or “our”) is committed to protecting and respecting your privacy.
This Privacy and Cookies Policy (“Notice”) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us and our partners. Please read this Notice carefully to understand our views and practices regarding your personal data and how we will treat it.
We provide database solutions for persons in the journalism, media, and/or public relations (“PR”) industries throughout the world (“Services”). Such persons include corporations in these industries and their employees, as well as employed or freelance journalists, bloggers and PR professionals and media contacts working in agencies or in-house at corporations and governmental organisations across different business sectors (“Users”). As part of our Services, from time to time we also publish media alerts by way of e-mail (“Telum Media Alerts”).
Specifically, in relation to the Telum Media Database and the personal data included on the Telum Media Database, please see the section below titled “The Telum Media Database”.
Quick Guide to Contents
- Changes to this Notice
- How to contact us
- Information collection
- Use of your information
- Legal basis for processing
- Disclosure of your information
- The Telum Media Database
- Transferring information to another country
- Google analytics
- Links to other websites
- Your rights
Changes to this NoticeWe may change this Notice from time to time, to reflect changes at Telum, or for legal or regulatory reasons. Unless we are unable to do so, we will give you reasonable notice of any changes to this Notice, which may be by notifying you via email and/or by posting an updated version on our website.
How to contact usQuestions, comments and requests regarding this Notice are welcomed and should be addressed to firstname.lastname@example.org.
For information about how to obtain a copy of your personal data or how to update your personal data, please see section below entitled “Your rights”.
Our data protection officers, with responsibilities for Telum’s data protection obligations under all applicable privacy laws, including in respect of the EU’s General Data Protection Regulation (to the extent applicable), are Nick Webster and Jonny Webster and they can be contacted on email@example.com.
Information collectionWe collect information about you:
- that you provide by filling in forms on this site. This includes information which you provide when registering to use the Services such as your name, email and other contact information, biography and work history information;
- if you contact us, we may keep a record of that correspondence; and
- when you visit this site (see also under Cookies below).
Use of your informationWe use the information you provide in order to identify you, communicate with you, to conduct our business, and provide the Services. Our use of collected information may include (but is not limited to):
- facilitating collaborations and communications between you and the Users;
- assisting Users to contact you in connection with journalism, media and/or PR purposes via the Services;
- for the purposes of fraud prevention;
- servicing our relationship with you (including providing you with updates on our Services);
- providing you with better customer service;
- contacting you to provide the notifications required under laws or regulations (e.g. in accordance with the Spam Act 2003);
- billing and account management;
- evaluating the effectiveness of our business strategy, and for statistical analysis;
- research and development in improving our Services and in developing new products and Services;
- sharing your information to registered Users of the Services; and
- monitoring and maintaining our computers and network.
Your information may be shared with other members of our corporate group, with locations throughout the world, including currently Singapore, Hong Kong, Malaysia, Australia and the UK, for uses as described above. Please see the “Transferring information to another country” section for further details about international transfers.
We do not undertake any decisions based solely on automated processing that has legal effects or otherwise significantly affects you.
Legal basis for processingWe will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you (or your organisation, as applicable).
- Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests. Our legitimate interests are as set out in the “Use of your information” section above.
- Where we need to comply with a legal or regulatory obligation.
- Where we have your consent to do so.
Disclosure of your informationWe may disclose your personal data to any member of our corporate group for uses as described above.
We may also disclose your personal data to third parties:
- if 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 Telum Media Group PTE Ltd or substantially all of its assets are acquired by a third party, in which case personal data held by it about its Users and customers will be one of the transferred assets; and
The Telum Media DatabaseThe relationship between public relations professionals and journalists is well known and long established. Telum prides itself on the extent and accuracy of its database of media contacts (which includes journalists, bloggers and other media contacts). We refer to this database as the “Telum Media Database”. The Telum Media Database facilitates more effective communications between public relations professionals and journalists. We collect and store the personal data for both parties and allow public relations professionals access to journalist contact details to allow them to perform the legitimate business of contacting and interacting with them.
The extent and accuracy of the Telum Media Database depends on the personal data that Telum collects/obtains. This section of the Notice describes how we collect/obtain and use personal data for the Telum Media Database. This section should be read together with the rest of this Notice which also applies to the personal data on the Telum Media Database.
What information do we collect/obtain about individuals on the Telum Media Database?
In addition to the kinds of personal data mentioned above in this Notice, we may also collect/obtain the following kinds of personal data of individuals who work in the journalism, media and/or PR industry:
- job title;
- contact information (including mobile phone number and personal email if provided to us or published);
- career history;
- industry awards and nominations;
- articles written; and
- areas of journalism interest and other relevant journalistic information in connection with the individuals and their role.
How do we collect/obtain personal data about individuals on the Telum Media Database?
The personal data in relation to individuals on the Telum Media Database comes from a variety of sources, including, in particular:
- direct from the relevant individuals (e.g. when signing up for one of our Services, such as Telum Media Alerts, or when responding to a request for information from Telum);
- from media outlets (e.g. newspapers, magazines etc.), who will periodically provide information relating to individuals employed by or connected with them (e.g. current job titles, contact information, areas of journalism interest);
- from publicly available sources (e.g. news stories, award submissions, press releases, online media etc.); and
- from other third party sources (e.g. information provided by Users or other contacts, including out-of-office messages).
How do we use the personal data on the Telum Media Database?
In addition to the uses mentioned above in this Notice:
- Users of our Services may have access to the personal data on the Telum Media Database and subscribers to the Telum Media Alerts may be sent alerts providing information about changes to the Telum Media Database (e.g. changes in job titles, journalist moves and contact information); and
- Users may contact individuals whose personal data is on the Telum Media Database directly (using the business contact information on the Telum Media Database) to e.g. send press releases or other PR material which may be considered to be of interest to the individuals in question. Telum does not control and is not responsible for the content of any such communications.
How do we maintain the Telum Media Database?
- Where appropriate, we will notify the relevant individual and may choose not to make any changes to their information on the Telum Media Database until they have been approved by the relevant individual.
- Individuals whose information is on the Telum Media Database always have the opportunity to review and request changes to such information.
- If any individual would like to review the personal data relevant to them on the Telum Media Database or would no longer wish to be on the Telum Media Database, they may email firstname.lastname@example.org. We will respect the rights of any individuals under applicable laws, including by updating or deleting any personal data, upon request. Please see the “Your rights” section below for further details.
- If we receive a request from an individual to delete their personal data from the Telum Media Database, we will exclude such data from being accessible by the Users. In order to ensure that such data will not become accessible by the Users in the future again and similarly-named individuals are not confused, we will retain the following information concerning the individual in question: (a) their name; (b) the publication(s) they work for; (c) their email address and (d) a log of the request (e.g. the email record) with an internal administrative note (if such information is on the Telum Media Database). None of this information is visible to the Users. If the individual requests that we do not retain any of their personal data, we will do so but as a result we may not be able to prevent their data from being added to the Telum Media Database again in the future.
- All our staff receive regular training in our data protection policies.
How long does Telum hold your data?
- We only retain your information for as long as is necessary for us to use your information as described in this Notice, where it is in our legitimate interest, or to comply with our legal obligations.
- When determining the relevant retention periods, we will take into account factors including:
- our contractual obligations and rights in relation to the information involved;
- legal obligations under applicable law to retain data for a certain period of time;
- our legitimate interest where we have carried out a balancing test;
- statute of limitations under applicable laws;
- (potential) disputes;
- if you have made a request to have your information deleted; and
- guidelines issued by the relevant data protection authorities.
- We are constantly verifying the data held on our database to ensure it is accurate. In the event that a journalist leaves the industry, we will do our best to remove them from our database. Telum aims to verify our database every six months.
From within the EEA to outside the EEA
We may need to transfer personal data from within the European Economic Area (EEA) outside of the EEA, including to:
- Hong Kong
From within another country (not in the EEA) to outside of that country
We may need to transfer personal data outside of a country, for example from Singapore to Australia. When we send your information from a country (not in the EEA) outside of that country then we will make sure that your information is protected to at least the same standard as that which is required in the originating country. We will always ensure that there is a proper legal mechanism that covers the data transfer.
SecurityWhere we have given you a password which enables you to access certain areas of this site you are responsible for keeping that password confidential and the password should not be shared with anyone.
All personal data you provide to us is stored on secure servers.
Access to your personal data is limited to employees we believe reasonably need to use that information in order to perform their roles in providing or developing our Services.
Finally we are committed to protecting your personal data. We put in place safeguards including robust and appropriate technologies, processes, and contractual arrangements, so that the data we have about you is protected from unauthorized access and improper use.
CookiesIn order to improve this site, we may use small files commonly known as "cookies". A cookie is a small amount of data which often includes a unique identifier that is sent to your computer or mobile phone (referred to in this Notice as a 'device') from this site and is stored on your device's hard drive.
A cookie records on your device information relating to your internet activity (such as whether you have visited this site before). The cookies we use on this site won't collect personal data about you and we won't disclose information stored in cookies that we place on your device to third parties.
These cookies are essential to the proper functioning of many features of this site. These cookies store a unique ID so this site can remember you from one page request to the next. If you disable cookies, you may not be able to access all the features of our Services.
Google analyticsWe use software called Google analytics which is a web analytics service provided by Google Inc. in order to understand how visitors to this site use the site. The Google analytics cookies remember you from one page request to the next, for example to differentiate between 'new' and 'returning' visitors. We receive reports from Google Inc. about website usage (such as the number of visitors to our site or the number of unique page views).
Links to other websitesThis site may contain links to other websites. This Notice only applies to this site so when you link to other websites you should read their privacy policies.
Your rightsYou may choose to remain anonymous to us by withholding identifying information or refusing offers to join our mailing list. If you choose to decline to provide certain personal data to us, you may not be able to access certain features of our Services.
Personal data collected by us will be used only for purposes outlined in this Notice. If we propose to use your information for any other purpose then, depending on the nature of the new usage, we will notify you and/or obtain your consent (where required) to the new usage.
In addition, you have a number of rights by law when it comes to your personal data – please see below for further details. Please contact us at email@example.com to exercise any of your rights. Further information and advice about your rights can be obtained from the data protection regulator in your country.
|Rights||What does this mean?|
|1||The right to object to processing||You have the right to object to certain types of processing, including processing for direct marketing (i.e. if you no longer want to be contacted with potential opportunities).|
|2||The right to be informed||You have the right to be provided with clear, transparent and easily understandable information about how we use your information and your rights. This is why we’re providing you with the information in this Notice.|
|3||The right of access||
You have the right to obtain access to your information (if we’re processing it), and certain other information (similar to that provided in this Notice).
This is so you’re aware and can check that we’re using your information in accordance with data protection law.
|4||The right to rectification||You are entitled to have your information corrected if it’s inaccurate or incomplete.|
|5||The 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 information where there’s no compelling reason for us to keep using it. However, your right to erasure does not apply if processing of your personal data is necessary, amongst other things, to exercise the right of freedom of expression and information, to comply with a legal obligation, and/or for the establishment, exercise or defence of legal claims.|
|6||The right to restrict processing||You have rights to ‘block’ or suppress further use of your information. When processing is restricted, we can still store your information, but may not use it further. We keep lists of people who have asked for further use of their information to be ‘blocked’ to make sure the restriction is respected in future.|
|7||The right to data portability||You have rights to obtain and reuse your personal data for your own purposes across different services. For example, if you decide to switch to a new provider, this enables you to move, copy or transfer your information easily between our IT systems and theirs safely and securely, without affecting its usability.|
|8||The right to lodge a complaint||You have the right to lodge a complaint about the way we handle or process your personal data with your national data protection regulator.|
|9||The right to withdraw consent||If you have given your consent to anything we do with your personal data, you have the right to withdraw your consent at any time (although if you do so, it does not mean that anything we have done with your personal data with your consent up to that point is unlawful). This includes your right to withdraw consent to us using your personal data for marketing purposes.|
We usually act on requests and provide information free of charge, but may charge a reasonable fee to cover our administrative costs of providing the information for:
- baseless or excessive/repeated requests, or
- further copies of the same information.
Last updated: 24 August 2018