Privacy notice

Early Morning Media Limited (“Early Morning Media”, “we”, “us” or “our”) takes your privacy seriously and is committed to protecting your personal information.

This privacy notice explains how we collect, use, store and protect personal information when you:

• visit earlymorningmedia.co.uk;
• contact us or submit an enquiry;
• request a sample, consultation or information about our services;
• subscribe to or receive one of our newsletters, briefings or other editorial products;
• communicate or do business with us; or
• otherwise interact with Early Morning Media.

It also explains your rights and how to contact us if you have questions about the way we use your personal information.

Early Morning Media Limited is the data controller responsible for the personal information described in this notice.

1. Who we are

Early Morning Media Limited is a UK-based provider of business intelligence, newsletters, executive briefings and related editorial services.

For privacy enquiries, please contact us using the details on our Contact page or at dataprotection@earlymorningmedia.co.uk.

2. Personal information we collect

The personal information we collect depends on how you interact with us.

It may include:

• your name;
• business email address;
• organisation;
• job title or role;
• telephone number;
• postal or business address;
• information you provide when contacting us;
• newsletter and briefing subscriptions;
• marketing preferences;
• records of communications with us;
• information relating to services supplied to you or your organisation; and
• technical information associated with your use of our website, such as IP address, browser type, device information and website usage data.

We aim to collect only the information reasonably necessary for the relevant purpose.

We do not intentionally collect special category personal information through this website, such as information concerning health, ethnicity, religious beliefs, political opinions or sexual orientation.

Please do not provide this type of information through our website unless it is necessary for a specific reason.

3. How we collect personal information

We may collect personal information directly from you when you:

• complete a form on our website;
• request a sample edition;
• subscribe to a newsletter or briefing;
• contact us by email, telephone or another communication channel;
• request a consultation;
• enter into a business relationship with us; or
• communicate with our team.

We may also obtain business contact information from other appropriate sources, including:

• publicly available business websites;
• Companies House and other public registers;
• professional and trade organisations;
• publicly available professional information;
• clients who engage us to produce or distribute communications on their behalf; and
• other legitimate business sources.

Where we obtain personal information from another source, we will process it only where we have an appropriate lawful basis and will comply with applicable data-protection and electronic-marketing requirements.

4. How and why we use your personal information

UK data-protection law requires us to have a lawful basis for processing personal information.

Depending on the circumstances, we may rely on consent, performance of a contract, compliance with a legal obligation or our legitimate interests.

Responding to enquiries

We use information submitted through our website or provided directly to us to respond to enquiries, provide requested information, arrange consultations and communicate with you.

Our lawful basis will normally be our legitimate interests in responding to business enquiries or taking steps at your request before entering into a contract.

Providing newsletters, briefings and services

We use subscriber and customer information to provide newsletters, briefings, samples and other services that have been requested or agreed.

Our lawful basis may be performance of a contract, taking steps before entering into a contract or our legitimate interests in providing the requested service.

Sample editions and trials

Where you request a sample or trial, we use your contact details to deliver it and, where appropriate, to communicate with you about your request.

We may also offer relevant business contacts a limited trial or sample of one of our professional briefing services where we reasonably believe that the service is relevant to their professional role and where doing so is permitted by applicable law.

Marketing and service updates

If you specifically ask to receive marketing communications or select an optional marketing preference on our website, we may use your details to send relevant information about Early Morning Media services, newsletters, briefings or developments.

Where consent is required, we rely on your consent.

In some business-to-business circumstances, we may rely on our legitimate interests to contact relevant corporate contacts about services that we reasonably believe may be relevant to their professional responsibilities, where applicable law permits us to do so.

We consider the nature of the recipient, the source of the information, the relevance of the communication and its likely impact before relying on legitimate interests.

You can object to direct marketing or unsubscribe at any time.

Operating and improving our business

We may process personal information where necessary to:

• administer our website and services;
• maintain accurate business and customer records;
• improve our newsletters, briefings and services;
• analyse the performance and use of our services;
• maintain information and network security;
• prevent misuse or unauthorised access;
• carry out internal administration, quality assurance and training; and
• manage our commercial relationships.

We generally rely on our legitimate interests in operating, protecting and improving our business for these activities.

Legal and regulatory obligations

We may process information where necessary to:

• comply with applicable laws and regulations;
• respond to lawful requests from regulators or public authorities;
• establish, exercise or defend legal claims;
• meet accounting, tax or auditing requirements; or
• comply with licensing, copyright or other regulatory obligations relating to our services.

Our lawful basis is compliance with a legal obligation or, where appropriate, our legitimate interests.

5. Newsletters and direct marketing

We provide specialist newsletters and briefings aimed primarily at professional and business audiences.

Where applicable, our marketing activities are carried out in accordance with UK data-protection law and the Privacy and Electronic Communications Regulations.

Every marketing email we send will provide an appropriate method of opting out, such as an unsubscribe link.

You may ask us to stop using your personal information for direct marketing at any time.

If you unsubscribe, we may retain limited information on a suppression list. This allows us to record that you have opted out and helps prevent you from being inadvertently contacted again.

Unsubscribing from marketing does not necessarily prevent us from sending essential service communications relating to a service you continue to use.

6. Cookies and website analytics

Our website uses essential technologies necessary for it to operate.

Where we use non-essential cookies or similar technologies, including analytics or marketing technologies, these will only be activated in accordance with applicable consent requirements.

You can accept or reject non-essential cookies and change your preferences using the cookie controls provided on our website.

Further information is available in our Cookie Notice.

7. Who we share personal information with

We do not sell personal information.

We may share information with trusted organisations that help us operate our business and provide our services, such as:

• website hosting and technology providers;
• cloud hosting and data-storage providers;
• email and newsletter-distribution providers;
• customer relationship management and business administration providers;
• analytics providers;
• professional advisers, including accountants, auditors and legal advisers;
• contractors and suppliers working on our behalf;
• regulatory bodies, law-enforcement authorities or public bodies where legally required; and
• clients where we are providing a service on their behalf and the sharing is necessary for that service.

Where a supplier processes personal information on our behalf, we require it to process the information only for authorised purposes and to provide appropriate protection.

We may also disclose information in connection with a merger, acquisition, restructuring or sale of all or part of our business. Where appropriate, information will be anonymised or access restricted before disclosure.

8. Client-provided information

In some cases, an organisation may engage Early Morning Media to prepare or distribute a newsletter, briefing or other communication to contacts identified by that organisation.

The respective responsibilities of Early Morning Media and the client for personal information used in these circumstances will depend on the service being provided and the relevant contractual arrangements.

Where we process personal information solely on a client's instructions, we will do so in accordance with those instructions and applicable data-protection requirements.

9. International transfers

Some of the technology providers and other suppliers we use may process information outside the United Kingdom.

Where personal information is transferred internationally, we will ensure that an appropriate legal mechanism is used where required.

Depending on the destination and circumstances, this may include:

• a UK adequacy regulation;
• appropriate contractual safeguards; or
• another transfer mechanism permitted under UK data-protection law.

We also take reasonable steps to ensure that suppliers handling personal information maintain appropriate security standards.

10. How long we keep personal information

We keep personal information only for as long as reasonably necessary for the purpose for which it was collected, including where necessary to meet legal, accounting, contractual or regulatory requirements.

The appropriate retention period depends on factors including:

• the nature of the information;
• why we collected it;
• whether you continue to use our services;
• applicable legal requirements;
• whether the information may be required in connection with a dispute or claim; and
• our legitimate business requirements.

When information is no longer required, we will delete it, anonymise it or securely dispose of it.

Where you have opted out of direct marketing, we may retain the minimum information required on a suppression list so that we can respect your preference in the future.

11. Security

We take appropriate technical and organisational measures to protect personal information against accidental or unlawful loss, disclosure, alteration, destruction or unauthorised access.

Access to personal information is restricted to people who have a legitimate business need to access it.

Those handling personal information are required to do so appropriately and confidentially.

We maintain procedures for responding to suspected personal-data breaches and will notify affected individuals and the Information Commissioner's Office where legally required.

12. Your rights

Depending on the circumstances, UK data-protection law gives you rights concerning your personal information.

These may include the right to:

• request access to personal information we hold about you;
• ask us to correct inaccurate or incomplete information;
• ask us to delete your personal information;
• request that we restrict the way we process your information;
• object to certain processing;
• object at any time to the use of your personal information for direct marketing;
• request the transfer of certain information to you or another organisation;
• withdraw consent where processing is based on consent; and
• raise a complaint about the way your information is being processed.

These rights are subject to certain legal conditions and exemptions.

You will not normally have to pay a fee to exercise your rights.

We may need to ask for information to confirm your identity before responding to a request.

13. Withdrawing consent

Where we rely on your consent, you may withdraw it at any time.

Withdrawing consent does not affect the lawfulness of processing carried out before consent was withdrawn.

For email marketing, you can normally withdraw consent by selecting the unsubscribe link contained in the email.

You can also contact us using the details provided below.

14. Your right to object to direct marketing

You have the right to object at any time to the use of your personal information for direct-marketing purposes.

If you exercise this right, we will stop using your information for that purpose.

We may retain limited information on a suppression list to ensure your preference continues to be respected.

15. How to make a privacy request

If you want to exercise your data-protection rights or have a question about how we use your information, please contact:

Please include enough information for us to understand and respond to your request.

16. Complaints

We would appreciate the opportunity to address any concerns you have about our use of your personal information.

You also have the right to complain to the UK's data-protection regulator:

Further information about making a complaint is available at ico.org.uk.

17. Third-party websites

Our website and newsletters may contain links to websites operated by other organisations.

We are not responsible for the privacy practices of third-party websites. We recommend reviewing the privacy information provided by those organisations before supplying personal information to them.

18. Changes to this privacy notice

We may update this privacy notice from time to time to reflect changes to our services, technology, business practices or legal requirements.

The most recent version will be published on this page and the "Last updated" date will be revised accordingly.

Where a change materially affects the way we use personal information, we will take appropriate steps to bring the change to the attention of affected individuals.

19. Contact us

For questions about this privacy notice or the way Early Morning Media handles personal information, please contact us through our website or using the following details: