To which Konex Media entity does this Notice apply?
This Privacy and Cookies Notice (“Notice”) applies to the website(s) of Konex Media Group Limited and its wholly owned subsidiaries and any other website of Konex Media Group subsidiary or affiliated companies which can be viewed here (“Konex Media”, “we,” “us,” or “our”) as well as any Mobile Apps, online forms and subscriptions, products or services, and social media channels controlled by Konex Media where a link to this Notice is provided (each, the “Platform” and together, the “Platforms”).
Why is this Notice important?
Konex Media is committed to protecting your Personal Data in accordance with our internal policies and applicable legislation.
This Notice informs you of our practices with respect to the collection, use and disclosure of Personal Data which you provide to us via our Platforms, in relation to any promotions, competitions, offers or marketing campaigns we carry out or which you provide for your potential employment with us. It also describes your data protection rights, including a right to object to some of the processing which Konex Media carries out. More information about your rights, and how to exercise them, is set out in the “Your Rights” section.
“Personal Data” means personal information that identifies you as an individual or relates to an identifiable individual as defined under applicable legislation in your territory .
How do we collect Personal Data and why?
The Data Controller is Konex Media Group Ltd.
We may collect your Personal Data in the following circumstances:
1. With your consent:
• when you subscribe to our marketing lists, social media pages, (promotions, competitions, offers or marketing campaign communications (together, “Marketing and Promotions”) will be provided to you by Social Media Channels, email, post or other communication channels); and
• If you choose to actively engage in an experiential campaign via, for example, a QR code on an interactive advertisement or competition and we need to know your identity or request your contact details, we will obtain your consent and tell you at the time of requesting that consent, how we will use that data.
2. To perform our contractual obligations:
• under our terms when you register for our Products or Services;
• to verify your identity
• when you register to attend a Konex Media event;
• provide customer service related to our Products and Services;
• when forming leasing or similar arrangements over assets; and
• If you apply to work for a Konex Media business we may need to take steps that are necessary prior to entering into an employment contract with you such as checking your qualifications or your right to work in the country you applied for a role.
3. For our legitimate business interests, which include:
• sending you communications about Marketing and Promotions if we do not need your consent • to provide you with access to Products and Services or specific materials or information from our Platforms that you request;
• processing your feedback and contributions to customer surveys, competitions, offers or questionnaires. • recording telephone calls with you for training and/or monitoring purposes;
• reviewing your queries so we can better help you or investigate any complaints received by you; and
• to improve our service to analyse trends to administer our Platforms; and
• to monitor our diversity and inclusivity.
• to help identify you for administrative purposes;
4. For compliance, legal or regulatory purposes:
• to verify your identity as part of the employment screening process, and for money laundering regulation purposes; • to report any activity which we suspect breaches any relevant laws or regulations to the appropriate authority.
What Personal Data do we collect?
Types of Personal Data
Personal Data we ask for includes but is not limited to combinations of information about:
• Your name, postal address, email address phone number, occupation and other contact information; • If you are a landlord, the details of your ownership of assets;
• Sensitive Personal Data such as race or gender, when applying for a position with us – please see the Sensitive Personal Data section below;
• where you heard about us;
• details of complaints;
• any information you may voluntarily submit to us by completing any form on our Platforms; and, such as a “free text” boxes on our Platforms (i.e. blank spaces where you are free to insert comments);
• your dealings with us including information regarding your personal or professional interests, needs or opinions, demographics, experiences with our Products or Services and contact preferences;
• if you are a job applicant your CV details and any background information we may receive from your referees, your LinkedIn profile, the recruitment agency that you work with (if any);
• details of financial or accounting transactions carried out on our Platforms or otherwise, including credit/debit card information, billing information and/or delivery address information (if you pay for anything on our websites); and/or • demographic and contact information from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties;
• technical information, including location information, the Internet Protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform.
• your online browsing behaviour on our Platforms; including the Uniform Resource Locators (URL) clickstream to, through and from our Platforms or Social Media Channels (including date and time), download errors, lengths of visits to certain pages, page interaction information (such as scrolling, clicks and mouse-overs) and methods used to browse away from the page;
• any devices you have used to access our Products and Services (including the make, model and operating system, IP address, browser type and mobile device identifiers).
In some circumstances, we request additional Personal Data to help us to provide you with the most appropriate response. If you do not provide the Personal Data where requested, your access to the service, or our ability to assist you, may be restricted.
Sensitive or “Special Category” Personal Data
We may ask, if your local law allows, for your voluntary provision of race, religion and other Sensitive Personal Data as part of the Konex Media recruitment process, to monitor our equality and diversity obligation (you can always decline to tell us).
Where permitted or required by law (which varies by jurisdiction), we will request that you self-declare pertinent current health conditions in order to allow you access to our premises, in accordance with government guidelines on public health. We keep our procedures under review to ensure they comply with recommendations in your jurisdiction. If we are required to process your Sensitive Personal Data for any other repurpose, we will, where required by law, ask for your explicit consent.
Sensitive or “Special Category” Personal Data means Personal Data which may relate to: racial or ethnic origin, political opinions, trade union memberships, physical or mental health conditions or, genetic or biometric data that uniquely identifies him/her, sex life or sexual orientation, religious or philosophical beliefs and the commission or alleged commission of any offence or related proceedings. Where you do provide Sensitive Personal Data, we will keep it securely and for a proportionate amount of time, and only use that information in connection with the purpose for which it has been provided.
Use of Anonymised Data
We may purchase, or collect, anonymised, aggregated datasets relating to the performance of our Out Of Home advertising (such as billboards, street, roads, highways, transit etc.), or anonymised and aggregated transaction and purchase history from data providers. We do this to better understand the types of people who will see the advertisements we promote, on behalf of our advertisers. We do not seek to analyse Personal Data.
SDK and Beacon Data
Beacons are installed on our panels in a number of prestige sites (currently not used at scale) and they passively transmit a location signal, which can be detected by mobile devices. Your phone may try to connect to the beacon installed in our billboards. From time to time we engage with data partners which use SDKs in apps to detect the presence of the signal. SDK stands for “software development kit”, it is a piece of code that is built into an app that facilitates that app to collect location data. When these apps are installed, the user has the option of giving their consent to enable the collection of their location data to enhance their app usage. These apps provide a dataset that helps data partners best understand consumer journeys and where people go in the real world. The app providers may also send you targeted messages if they have appropriate consent in accordance with their privacy notice. However, all location data used by Konex Media, that is transmitted by its partners, are aggregated and anonymous and we do not identify, track or target individual people.
Computer vision software on our panels
Computer Vision software is in standard use across the Out Of Home Advertising industry (such as billboards, street, roads, highways, transit etc.). When this technology is used, a camera installed within the screen is enabled which can recognise the basic characteristics of people (for example your gender and hair colour etc.) looking at the screen in order to personalise the advertisement they see. For example, an interactive advertisement might show a pair of sunglasses on a female or male character depending on the gender of the person looking at the screen.
Our partners may process your Personal Data through their computer vision software that is embedded into our billboards when you pass by one of our advertising billboards, in order to measure your engagement with the advertisements we promote (such as the length of time you looked at the advertisement, or expressions). They then transfer to us the anonymised, aggregated datasets for us to better understand demographic audience reactions to the advertisements we promote, on behalf of our advertisers.
Personal Data capture software is subject to strict deidentification, information security and memory wiping procedures. We engage software providers that have been subject to data privacy impact assessments and signed terms agreeing to abide by Applicable Data Protection Legislation.
Under the GDPR and other applicable legislation, you have rights over your Personal Data. Those rights include (subject to legal and regulatory requirements):
Right to Rectification of Personal Data
If you advise us that your Personal Data is no longer accurate, we will amend or update it (where practical and lawful to do so).
Right to Erasure or Restriction of Processing of Personal Data
You can ask us to delete or restrict processing of your Personal Data in some circumstances such as where we no longer need it or you withdraw your consent (if we rely on your consent for processing). If we’ve shared it with others, where possible, we’ll let them know about the erasure.
Right to Withdraw Consent
You have an absolute right to opt-out of direct marketing, or profiling we carry out for direct marketing, at any time. If, at any time, you have consented to us processing your Personal Data in the circumstances or purposes described above, and you no longer wish to have your Personal Data processed in this way, you may unsubscribe by pressing any unsubscribe facility or by emailing firstname.lastname@example.org.
Right to Portability
You can ask us to provide you with your personal data (that you provided to us or that we observed through your activities on our Platforms) in a commonly used and machine-readable format to send it to another controller.
Right to Object
You can object to the processing of your personal data in some circumstances (in particular, where we don’t have to process the data to meet a contractual or other legal requirement, or where we are using the data for direct marketing if we are not relying on your consent).
Rights in relation to Automated Decision-making and Profiling
You have the right not to be subject to a decision when it’s based solely on automated processing or profiling which produces a legal or similarly significant effect on you. We only carry out this type of decision-making where the decision is necessary for the entry into or performance of a contract; or authorised by Union or Member state law applicable to us; or based on your explicit consent.
We will always tell you if we do any such activity using your Personal Data.
Right to Access Personal Data
Where permitted by law, you may have the right to contact us to request a copy of Personal Data that we hold about you. Before responding to your request we may ask you to (i) verify your identity and (ii) provide further details so we can better respond to your request.
These rights may be limited, for example if fulfilling your request would reveal personal data about another person, where they would infringe the rights of a third party (including our rights) or if you ask us to delete information which we are required by law to keep or have compelling legitimate interests in keeping. Relevant exemptions are included in both the GDPR and in the Data Protection Act 2018. We will inform you of relevant exemptions we rely upon when responding to any request you make.
To exercise any of these rights, or to obtain other information, such as a copy of a legitimate interests balancing test, you can get in touch with us using the details set out below.
If you require further information on your rights or our use of your Personal Data, please contact us at email@example.com. If you have unresolved concerns, you have the right to complain to an EU data protection authority where you live, work or where you believe a breach may have occurred.
Children’s Personal Data
Our Platforms are not intended to target children under the age of 16. We will not knowingly collect or process Personal Data belonging to children via our Platforms.
Third Party Goods and Services
We will not send you information relating to third party goods and services from outside Konex Media unless specifically requested.
Third Party websites
Transfer of Personal Data
We transfer your personal data where we use third party service providers to help us process Personal Data for the purposes described in this notice, these will include customer management and intelligence solution providers, aggregated data analytics partners, web hosting facilities, audit and compliance partners.
Data Controller Intragroup Transfer
From time to time, it may be necessary for our legitimate interests to transfer Personal Data collected by Konex Media Group and its subsidiary company together with their data processors.
Transfers outside the European Union
Non-European countries may have data protection laws that are less protective than the legislation where you live. Where this is the case, (such as the United States), our transfers of Personal Data will be regulated by the EU Commission’s standard contractual clauses relating to the transfer of Personal Data outside of the European Union (or outside of jurisdictions deemed “adequate” for data privacy by the European Commission. The jurisdictions to which Personal Data are transferred may be conditional on your nationality or location.
Sale or Merger
If Konex Media or its assets are sold to or merge with another entity outside Konex Media, you should expect that some or all of the Personal Data collected by Konex Media may be transferred to the buyer/surviving company.
Retention of Personal Data
If you have provided us with Personal Data, your Personal Data will be retained for the duration of your relationship with us to fulfil the purposes for which we collected it. This includes, the length of time required to satisfy any legal, regulatory, accounting and reporting requirements , and to process personal information on you in order to establish or defend legal claims (and we or our third party data processors will amend or dispose of your Personal Data at the end of the relevant retention period).
In determining the appropriate retention period we consider the purpose for which we process your Personal Data, the volume, type and context of the Personal Data, local legal requirements, the risk of harm to the data protection rights of the individual and whether the purpose for processing Personal Data can be established through an alternative method.
For further information regarding the specific retention periods we apply to your Personal Data please contact us at firstname.lastname@example.org.
Personal data collected from applicants who are unsuccessful will be deleted or, if that individual may be of interest for other roles, kept until one year after the applicant submits their application.
Where we process personal data for marketing purposes or with your consent, we process the data until you ask us to stop and for a short period after this (to allow us to implement your requests). We also keep a record of the fact that you have asked us not to send you direct marketing or to process your data so that we can respect your request in future.
Where we process personal data in connection with performing a contract or for a competition, we keep the data for 6 years from your last interaction with us.
Should you wish to make any comments, complaints, enquiries or if you have any questions relating to this Notice, your rights, the Platform, our Marketing and Promotion materials or Products or Services we provide, you may contact the Konex Media Chief Data Privacy Officer by emailing or writing to the Privacy Office:
The Chief Data Privacy Officer
Konex Media Group Ltd
Accra Digital Centre
Ring West Road
You may also contact the Data Protection Authority where you live, work or believe the breach has happened.
Changes to this Notice
This Notice is subject to periodic review to ensure it is in line with applicable legislation.
We retain all applicable ownership rights to information we collect. We reserve the right to change, modify, add or remove provisions of this Notice. Any changes to this Notice will be posted here, and we encourage you to check back from time to time. If the changes are substantial, we will notify the changes to you.
Our website address is: https://konexmedia.co.