Blue Sky Media LLC

This Privacy Policy sets out the data processing practices carried out by us in relation to the information that we hold relating to you.

Blue Sky Media LLC complies with the 2003 CAN-SPAM Act and is also registered with the UK ICO under Registration Number ZA762438. Our registered office is Level 22, Tower One Exchange Plaza, Ayala Triangle Ayala Avenue, Makati City Metro, Manila 1226, Philippines and our company is incorporated in the Phillipines.

Blue Sky Media LLC has appointed The Preference Centre Ltd as our Data Protection Officer whose ICO Registration Number is ZA761923 and they can be contacted via their website www.thepreference.center or by sending an email to or by telephone on 0161 513 2343.

If you wish to find out more about the Data Protection Act 2018 and your rights then please visit ico.org.uk.

Our policy is both specific and strict. If you think our policy falls short of your expectations or that we are failing to abide by our policy, please let us know. In extreme cases data provided by you may be unlawfully available to hackers and snoopers, unfortunately we are unable to accept responsibility for this. The risk is no different from a similar risk of burglary, in a bricks and mortar establishment you can lock the doors but they may still find a way in. Except as set out below, we do not share, or sell, or disclose to a third party, any personally identifiable information collected on this site or any other site operated by Blue Sky Media LLC. If this policy should change in the future, then we will provide notification in advance and users have the opportunity to indicate whether or not they would prefer that we do not provide the information to third parties as proposed.

We are collecting your data to enable us to carry out our own marketing to you of our own products and services as well as products services and offers from others that we feel may be of interest to you.

We will also share your data for commercial gain, including Revenue Collection with third parties. These organisations will have a relationship with you or it may be used where they have a lawful reason, which may include these organisation's own legitimate interest.

Use includes tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, affordability assessments, asset recovery and asset reunification.

Your data will also be used for the purpose of analysis or to create a data product. In this case your information is aggregated in line with the ICO code of practice and anonymously used for marketing purposes.

We will share your data with the Marketing Service Providers specialist Marketing Agencies & Data Brokers listed who will use it to create products and services to help organisations better understand the likely characteristics of their customers, communicate with them more effectively and find others like them across a range of marketing channels.

This may mean that you receive advertising that is more relevant to you via direct mail or when you visit a website.

Additionally under data protection laws we are permitted to share some information where the reason for doing so is legitimate and isn't outweighed by the effects on the relevant individuals. On the basis, to help make advertising more relevant to you and full of offers that we hope you'll find relevant.

We provide the types of information detailed in the above section - The information we collect, hold and process to our Clients for the purpose of carrying out our and their business.

Some of our Clients we provide this information to so they can carry out their business as Marketing Service Providers and Marketing Agencies & Data Brokers.

We will also add your data to other data to create GEO and Wealth profiles which are based on postcode. This type of information is anonymised and does not directly relate to the consumer however it is a reflection of the postcode area

Consent

This is where you have consented to a specific organisation contacting you for specific reasons, using a communication channel or channels which you have agreed to. When we Blue Sky Media LLC contact you we will be doing so for marketing purposes. When we ask you for your consent for another organisation, we will do so by giving you the opportunity to tick a box online or answer a question on the phone to confirm your consent.

Any consented information you have previously shared with us or any third parties will be renewed at the time you consent for any new information sharing unless you indicate otherwise by contacting us.

You can always change your mind at any time and withdraw your consent for a specific channel or even globally by following this link Click Here

•We obtain consent for our brands to contact you by telephone where your number is registered on the Telephone Preference Service (TPS) or by email and SMS.
•To pass your contact details to named third parties where the Privacy and Electronic Communications Regulation (PECR) applies such as email marketing or where your telephone number is registered with the TPS.
•To pass your contact details to named third parties where your postal address is registered with the Mailing Preference Service (MPS).
•Where our client has specifically asked us to gain your consent to pass on your details.
•All cookies & similar technologies which do not meet the "strictly necessary" exemption under PECR.

Legitimate Interest:

GDPR (Recital 47) explicitly recognises the processing of personal data for direct marketing purposes as a legitimate interest.

As a direct marketing business we process personal information for various legitimate business purposes which include some or all of the following:

To enhance our services for the benefit of our customers including verification and validation
To help make the communication more relevant and contextual
To better understand how our customers interact with our services
To provide direct marketing communications which we think will be of interest to you
To determine the effectiveness of our and our clients promotional campaigns
To identify and prevent fraud
These legitimate business purposes relate to the following activities:

Direct Marketing - Postal and telephone marketing by both Blue Sky Media LLC and other third parties, but in either case communications will be in relation to products or services which we believe are of interest to you based upon information which you have provided us.

Profiling - We will profile your information for marketing purposes to help our clients deliver marketing communication that is more relevant to you (for more information, please refer to the profiling section)

ID Protection & Tracing - This is in relation to appropriate agencies which could help protect your identity and prevent fraud.

We process your data in the following ways:

To pass on your personal information to our clients for marketing purposes who will send postal marketing to you, (except where you are registered with the MPS) or contact you by telephone (except where you are registered with the TPS).

Marketing will only ever be from organisations operating within the industry sectors , Charity, Financial, Holidays and Travel, Insurance, Legal, Lifestyle, Media, Motoring, Shopping, Family & Home and here's examples of Companies who may use your data.

To call you where your telephone number is not registered on the TPS.

To call you where we have obtained your details from a third party. We will always be named within their privacy policy as a party to whom they share your information once contact is made we will obtain your consent at the earliest opportunity. You will always be given the option to opt out should you not wish to hear from us again.

To process your personal information for the purposes of customer analysis, non-automated profiling and direct marketing, to help us with our activities and to provide you with the most relevant information as long as this does not harm any of your rights and interests.

To pass to our clients for use including tracing of individuals, verification and/or validation of the identity of individuals for the purposes of, but not limited to, anti-money laundering regulations, national security, crime prevention and detection, anti-fraud processes, affordability assessments, asset recovery and asset reunification. More information on this can be found in the Credit References and other Agencies section.

To determine the effectiveness of our clients promotional campaigns and advertising, and to develop our products, services, systems and relationships with you.

Processing your information to protect you against fraud when using our website, and to ensure our websites and systems are secure.

To pass on your details to companies to help their clients tailor products and services which best suit your needs. They will also use your data for fraud prevention.

It is important that we keep your details up to date, therefore we use various methods such as the information detailed in the Information we Process section of this Privacy Policy..

For all types of processing, we apply various measures to carefully protect your privacy rights. In considering the most appropriate legal basis, Blue Sky Media LLC conduct Legitimate Interest Assessments which are detailed evaluations of each type of data processing activity to ensure that we have balanced the need of the processing against the rights of the individual to ensure minimal privacy impact.

The law does not put a time limit on the length of time we can hold your personal data, Blue Sky Media LLC will only retain your data for as long as it is required for the purposes for which it was collected for as long as it remains accurate and up-to-date and most importantly, for as long as long as you are happy for us to do so.

You can withdraw your consent globally and also opt out from receiving marketing messages via specific method by registering this with The Preference Centre Click Here.

Your personal information that has been collected will be held by us for a maximum period of twenty years from the most recent date of permission.

We will regularly communicate with you via any of the channels that you have consented to, and using those channels we will provide ongoing reminders of your data subject rights with access to this privacy policy.

We refer to this as activity as engagement or notification recency and our data retention policy considers the purpose, the legal basis under which it is processed and also the most recent engagement. If consent is given again then the period of retention will commence again from that date.

Marketing:
Where we process your data under consent we will stop using it for marketing purposes after five years.
Where we rely on legitimate interests we will continue to process your data for ten years, subject to receiving notification from ourselves that we hold your information.

Profiling
We will stop using your data for this purpose after ten years.

Tracing and Credit Reference
This purpose plays an important function of protecting individuals, we will retain your data for twenty years. However, we will retain only basic name, date of birth and contact information for this purpose.

In addition, when completing lifestyle questions you may provide us with information such as the make and model of your car or the newspaper you read. Where information such as this has less use over time, it will be removed sooner than the retention periods detailed above.

It is important that the personal data we hold and process is accurate and up-to-date. Therefore, we regularly refresh the database against suppression lists and remove those who no longer wish to be contacted.

We will hold suppression data as long as it is necessary to ensure that we cannot market to you, supply your personal data or receive it into our systems for processing.

You have a number of rights under GDPR

A. Right to be informed - When we collect your data we have to tell you what we are going to do with it primarily through this Privacy Policy and consent statement.

B. Right of access - You have the right to contact us verbally or in writing to request details of the information we hold about you. You can withdraw consent in the following ways:
In writing to: Data Protection Office, The Preference Centre Ltd, 13th Floor, City Tower, Piccadilly Plaza, Manchester, M1 4BT
By email to:
or By telephone on: 0161 513 2343

C. Right of rectification - You have the right to ask us to rectify information that we hold about you if it is inaccurate or incomplete.

D. Right to erasure - This is also known as the right to be forgotten and gives you the right to request your information be removed if there is no compelling reason for its continued processing.

Please note that we keep a list of people who have asked not to be contacted which we use to ensure that you receive no further marketing from ourselves or clients as a result of our activity. Without this list your data could enter our system again from another source and we would have no record of the fact that you asked us not to contact you.

E. Right to restrict processing - This is the alternative to erasure and gives you the right to tell us to stop processing your data but allowing us to keep enough information about you to ensure that your wishes are respected in the future.

F. Right to data portability - This gives you the right to ask a holder of your information to transfer that information to another business. This right would most commonly used if you were switching banks, insurance companies, utilities companies and mobile phone providers.

G. Right to object - You have the right to object to the processing of your data for marketing purposes and profiling for marketing purposes. You also have the right to ask us to cease processing based on our legitimate interests, where there is no overriding justification for the processing of your data. Your rights and freedoms override our interests.

H. Rights related to automated decision making including profiling - We do not use automated decision making processes which would have a potentially damaging effect on you. But if we did you have the right to obtain human intervention, express your point of view, obtain an explanation of the decision and challenge it.

I. Right to withdraw consent at any time where relevant - You have the right to withdraw your consent to the processing of your information at any time and we must provide you with the information you need to do so, at the time we collect your data and each time we contact you.

J. Right to lodge a complaint with a supervisory authority - If we cannot deal with your complaint to your satisfaction you also have the right to complain to a relevant supervisory authority which include:
The Information Commissioners Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF, or call: 0303 123 1113 or online at https://ico.org.uk/concerns/ and The Advertising Standards Authority https://www.asa.org.uk/make-a-complaint.html

You can withdraw your consent globally and also opt out from receiving marketing messages via specific method by registering this with The Preference Centre Click Here.

We have also added some links to industry used suppression files that are free to record your data and this will be used by reputable marketing companies to suppress your details from their marketing activity.

Postal Marketing: you may register your opt out from receiving marketing materials by post using the following link: www.mpsonline.org.uk

Email or SMS messaging can be stopped by hitting the unsubscribe link in the emails sent to you or by replying to SMS messages with the word STOP.

Telephone calls can be prevented by registering your telephone number, mobile or landline with the Telephone Preference Service TPS using this link: www.tpsonline.org.uk

www.youronlinechoices.com is also a site that holds information as to what you can do to enhance your digital communications.

Changes to this Privacy Policy

We update this Privacy Policy from time to time and you should return to update yourself of any changes. If we make a major change to how we process your data, or why, we will notify you directly.

If you have questions regarding this privacy policy or your personal data then please contact The Data Protection Officer at Blue Sky Media LLC and they can be contacted via their website blueskymedia.pw or by sending an email to The Preference Centre Ltd at or by calling 0161 513 2343 during business hours.