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This privacy policy was last updated on 01/02/2024

Welcome to the Tomorrow Media Privacy Policy

Tomorrow Media Group Ltd (“Tomorrow Media”) respects your privacy and is committed to protecting your personal data.

 

When we refer to “we” or “us” in this Privacy Policy, we are referring to Tomorrow Media Group Ltd.

 

This Privacy Policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.

 

With that in mind, this Privacy Policy is designed to describe:

 

• Who we are.
• What we do.
• Cookies.
• What are “Your Rights” over your Personal Data.
• What Personal Data we collect.
• How we collect your Personal Data.
• How we use your Personal Data and why.
• Who we share your Personal Data with.
• Marketing.
• Lawful basis.
• How we keep your Personal Data secure.
• International Data Transfers.
• How long we store your Personal Data.
• Our policy on children.
• Changes to this policy.
• Third party Links.
• Contact Us.

EU-wide data protection legislation known as the “General Data Protection Regulation” or “GDPR”, took effect from May 25th, 2018.

 

Following the UK’s withdrawal from the European Union on 31st January 2020, the GDPR has been retained in domestic law as the “UK General Data Protection Regulation” or “UK GDPR” (a copy of which is posted here), but the UK has the independence to keep the framework under review. The UK GDPR sits alongside an amended version of the Data Protection Act 2018.

 

This website Privacy Policy is intended to meet our duties of Transparency under the GDPR, the UK GDPR and all other applicable privacy laws.

 

We will post any modifications or changes to this Privacy Policy on this page.

Who we are.

Tomorrow Media is a marketing agency that helps customers make buying decisions through a variety of independently run media channels. Our websites enable us to better understand customer behaviour(s) allowing us to match them to relevant products and services. 

 

Tomorrow Media owns and maintains the following website, emailing and comparison brands:
isave.co.uk, lookaftermybroadband.uk, lookaftermymobile.com, lookaftermyenergyuk, utility-switch.co.uk, Deadfastbroadband.com and Swicc.co.uk.

Our privacy policy is the same across all websites and brands we maintain, so you know it is us.

 

Our registered address is:

Tomorrow Media Group Ltd

Cali House, 3rd Floor
Vjal ir-Rihan, Triq tal-Balal
San Gwann
SGN9016
Malta

 

We have appointed a “Data Protection Officer”, this is a person who is responsible for overseeing and advising us in relation to our compliance with the GDPR and our compliance with this Privacy Policy. If you want to contact our Data Protection Officer directly, you can email: dataprotection@tomorrowmediagroup.com.

 

Our ICO registration number is: ZA627493

 

What we do.

Tomorrow Media are a UK consumer data controller. This means that we gather information about people via the websites above.

 

Our sites are designed to help you with money saving offers collecting information and then sharing that information with our listed clients who might be able to offer you a product or service to fit your needs.

 

Tomorrow Media is a data controller under the definitions of the UK GDPR.

Cookies.

Google Analytics is a simple, easy-to-use tool that helps website owners measure how users interact with website content. As a user navigates between web pages, Google Analytics provides website owners JavaScript tags (libraries) to record information about the page a user has seen, for example the URL of the page. The Google Analytics JavaScript libraries use HTTP Cookies to “remember” what a user has done on previous pages / interactions with the website.

 

Important: Read the Google Analytics privacy document for more details about the data collected by Google Analytics.

 

Google Analytics supports three JavaScript libraries (tags) for measuring website usage: gtag.js, analytics.js, and ga.js. The following sections describe how each use cookies.

 

This website uses cookies to improve your experience while you navigate through the website. Out of these, the cookies that are categorized as necessary are stored on your browser as they are essential for the working of basic functionalities of the website. We also use third-party cookies that help us analyze and understand how you use this website. These cookies will be stored in your browser only with your consent. You also have the option to opt-out of these cookies. But opting out of some of these cookies may affect your browsing experience.

 

Necessary Cookies are essential for the website to function properly. These cookies ensure basic functionalities and security features of the website, anonymously.

 

Name

Duration

Description

_gcl_au

3 Months

Google Tag Manager sets the cookie to experiment advertisement efficiency of websites using their services.

test_cookie

15 minutes

doubleclick.net sets this cookie to determine if the user’s browser supports cookies.

_ga_*

1 year 1 month 4 days

Google Analytics sets this cookie to store and count page views.

_ga

1 year 1 month 4 days

Google Analytics sets this cookie to calculate visitor, session and campaign data and track site usage for the site’s analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognise unique visitors.

_fbp

3 Months

Facebook sets this cookie to display advertisements when either on Facebook or on a digital platform powered by Facebook advertising after visiting the website.

What are “Your Rights” over your Personal Data.

Under data protection law you have rights regarding how we process your data.

 

You are not required to pay any charge for exercising your rights. We have one month to respond to you, and you may be asked for ID to confirm your identity.

 

To exercise any of the following rights, please use the contact details listed at the bottom of this section:

 

Your Individual Rights as a Data Subject

 

  • Right of access – you have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process. You can read more about this here
  • Right of rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies. You can read more about this here
  • Right to be forgotten – in certain circumstances you can ask for the data we hold about you to be erased from our records. You can read more about this here
  • Right to restriction of processing – where certain conditions apply you have a right to restrict the processing. You can read more about this here
  • Right of portability – you have the right to have the data we hold about you transferred to another organisation. You can read more about this here
  • Right to object – you have the right to object to certain types of processing such as direct marketing. You can read more about this here

 

By Email – dataprotection@tomorrowmediagroup.com

 

In Writing to – The Data Protection Officer, Tomorrow Media Group Ltd

  • Cali House, 3rd Floor
  • Vjal ir-Rihan, Triq tal-Balal
  • San Gwann
  • SGN9016
  • Malta

 

Our UK GDPR representative is the point of contact for all questions concerning the data protection of UK citizens and the contact for data protection supervisory authorities. Their contact details are as follows:

Ian Cruickshank – Lead 365 Ltd
Suite 3 Sanctus House, Olympus Park, Gloucester, Gloucestershire, England, GL2 4DH
dataprotection@lead365.co.uk

 

You can also withdraw your consent for live or automated calls from anyone by registering your telephone number on the Telephone Preference Service. Details can be found at www.tpsonline.org.uk

Right to lodge a complaint

If we cannot deal with your complaint to your satisfaction, you have the right to complain to the relevant supervisory authority who, in the UK is the Information Commissioner’s Office (ICO) are their contact details are:

 

The Information Commissioner’s Office

Wycliffe House, Water Lane, 

Wilmslow, Cheshire, 

SK9 5AF 

https://ico.org.uk/make-a-complaint/ 

Tel: 0303 123 1113

What Personal 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 about you to enable us to provide you with our price comparison, switching or other services, which we have grouped together as follows:

 

  • Identity Data includes first name, last name, internet protocol (IP) address and postcode.
  • Contact Data includes email address and telephone numbers.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

 

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will 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 policy.

 

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, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

How we collect your Personal Data

We use different methods to collect data from and about you including through:

  • Direct interactions. You may give us personal data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
  • fill in forms on our website;
  • search for a comparison;
  • enter into a contract for the supply of services;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey;
  • correspond with us by phone, email or live chat; or
  • give us feedback or contact us.
  • Third parties or publicly available sources. We will receive personal data about you from various third parties including the following:
    • analytics providers such as Google based outside the UK and EEA;
    • advertising networks based inside OR outside the UK and EEA; and
    • search information providers based inside the UK or the EEA.
    • Identity and Contact Data from data brokers or aggregators, such as Lead 365 Ltd – https://www.lead365.co.uk/privacy-policy/ based in the UK.

How we use your Personal Data and why.

We will only use your personal data when the law allows us to. We will obtain your consent before sending third party direct marketing communications to you. You have the right to withdraw consent to marketing at any time by contacting us.

 

Purposes for which we will use your personal data is 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.

 

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

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

Performance of a contract with you

To provide our services and fulfilling your requests

(a) Performance of a contract with you

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review or take a survey

(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 this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) 

(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

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

Necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, products/services, marketing, customer relationships and experiences

Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about our services that may be of interest to you

Necessary for our legitimate interests (to develop our products/services and grow our business)

To share your data with third party advertisers who will send relevant adverts to you

Your consent

 



Who we share your Personal Data with.

We may share your personal data with the external third parties set out below for the purposes set out in the table in the How we use your Personal Data and why section above.

 

Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy.

 

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.

 

When you complete an enquiry, you consent to us disclosing your personal information to the following parties:

 

  1. Tomorrow Media Group Ltd: to communicate with you, including sending you information about products and services which may be of interest to you within the switching sector and other money saving sectors listed below; in accordance with its privacy policy.
  1. Trusted third parties but only where you have opted in to allow us to do so. These companies may bring to your attention information about Products and Services that may be of interest to you and include such things that may help you save money, reduce debt, increase earnings, improve your credit rating, create more value for money, get better results and create benefits for you and your family. These companies may contact you where they have a lawful reason, which may include these organisation’s own legitimate interest.

Third Party Partners listed below:

Broadband

Telecommunications

Utilities

Retail and discounts

Marketing & Analytics

We may share your information with any of the Third Parties or Sub Processors listed below.

 

The table below details the Tomorrow Media’s purposes and legal bases when processing your personal information.

 

Recipients

Categories of Personal Data we share.

Why we share this Personal Data

Advertisers & Publishers

Account Information & Personal Data

We share in order for decisions to be made when forming partnerships. Following the formation of a partnership, we process personal data between data controllers and further information related to campaign performance, necessary to calculate payments/commissions. This is made in the form of Publisher ID in order to remain anonymous.

Hosting Provider

Account Information; Log Records

Our services are hosted by third parties sub processors. In order to facilitate our services, we have to pass data we hold (including your Personal Data) to our hosting provider.

Affiliates

Account Information; Log Records

As a group of companies, we rely on affiliates to provide certain services to us. All affiliates are required to adhere to the descriptions and specifications set out in this Interest

An acquirer or insolvency practitioner

Account Information; Log Records.

We may share Personal Data when we do a business deal, or negotiate a business deal, involving the sale or transfer of all or a part of our business or assets. These deals can include any merger, financing, acquisition, or bankruptcy transaction or proceeding. All counterparties will be required to keep such information strictly confidential.

Law enforcement agencies and regulatory authorities

Account Information; Log Records.

We may share Personal Data as we believe necessary or appropriate:
• to comply with applicable laws; and/or
• to comply with lawful requests and legal process, including to respond to requests from public and government authorities to meet national security or law enforcement requirements.

 

Consumers

Recipients

Categories of Personal Data we share.

Why we share this Personal Data

Advertisers

Your Personal Information, this could include, Name, Address, Date of Birth, Email address, Telephone numbers and any other non-sensitive information you may have shared with the data controllers.

To fulfil a contract.  The processing of your information could be done to either explicit consent or legitimate interest to facilitate the safe transfer between an advertiser and/or publisher that uses the services of Tomorrow Media Group Ltd.

Third Party Data Providers

Your Personal Information, this could include your Postal Address and Telephone Number that you may have shared with the data controllers.

To fulfil a contract. We may share your Personal Information with third party data providers who may append additional information about you or your postal address to your Personal Information and return to us for profiling and segmentation purposes. This may include information about your utility supplier, meter type and also your utility tariff. Using the appended data, Tomorrow Media Group will, under written instruction from an Advertiser that uses the services of Tomorrow Media, profile and segment your Personal Information to enable the Advertiser to determine and tailor relevant marketing offers and communications to you.

Third Party Advertisers

To share your data with third party advertisers who will append property level information including current energy supplier, meter type, meter install date and meter point administration number

(a) Necessary for our legitimate interests (to develop our products, services and clients)

Third Party Industry Sectors:

  • Industry Sectors you may be contacted from including those from which our third-party Partners are included. We may update our third-party partners and sector lists from time to time accordingly.

     

    Automotive / Retail / Finance / Gambling / Insurance / Travel / Lifestyle / General / Utilities / Security / Mobile

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

 

Promotional offers from us and partners.

 

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, services 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 used our services and you have not opted out of receiving that marketing.

 

We may share your data with other companies for carrying out/putting in place the product / services that we recommend and for reporting purposes.

Third-party marketing

We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you OR 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 to enable us to provide our price comparison, switching or other services to you.

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 obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

How we keep your Personal Data secure.

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.

International Data Transfers.

External third-party service providers who may process personal data on our behalf may be based outside the UK or EEA so their processing of your personal data will involve a transfer of data outside the UK or EEA.

Whenever we transfer your personal data out of the UK or EEA, we ensure a similar degree of protection is afforded to it by ensuring that appropriate safeguards are implemented. For example, we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data, where we have adopted standard contractual clauses approved for use in the UK and EEA to safeguard the data, or where a derogation applies (for example, if you have given consent to the transfer).

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK or EEA.

How long we store your Personal Data.

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

 

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, regulatory, tax, accounting or other requirements.

 

In some circumstances you can ask us to delete your data: see the What are “Your Rights” over your Personal Data section above for further information.

 

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Our policy on children.

Our websites, products and services are not intended for use by children under the age of 16. We do not knowingly collect data relating to children under the age of 16.

Changes to this Privacy Policy.

Changes to the privacy policy and your duty to inform us of changes.

We keep our privacy policy under regular review. This version was last updated on 01/02/2024. 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.

Third Party Links.

This 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 our website, we encourage you to read the privacy policy of every website you visit.

 

External Third Parties

 

  • Service providers acting as processors based in the UK who provide IT and system administration services.
  • Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers based in the UK.
  • HM Revenue & Customs, regulators and other authorities acting as processors or joint controllers based in the UK.
  • Third party advertisers with whom you have given your consent to us sharing your personal data for marketing and advertising purposes.
  • Institute of Chartered Accountants England & Wales

Contact Us.

If you contact us, we will use this information only to respond to and/or resolve your query/question. We will not share this with third parties for marketing purposes.


Our registered address is:


Tomorrow Media Group Ltd

Cali House, 3rd Floor

Vjal ir-Rihan, Triq tal-Balal

San Gwann

SGN9016

Malta

ICO Registration number : ZA627493

Please contact us via email: dataprotection@tomorrowmediagroup.com

COPYRIGHT 2024 TOMORROW MEDIA GROUP

PRIVACY POLICY