I. Terms of Business

  1. Definitions

    In these Terms of Business

    • Agreement means the contract between us and you for the supply of Services in accordance with the Engagement Letter and these Terms of Business, unless expressly agreed otherwise in writing from time to time.

    • We/us/GSM means Grey Seal Media Limited, a limited company registered in England with number 12578064 and with its registered office at 27 Old Gloucester Street, London, WC1N 3AX.

    • You means the recipient of our Services as specified in the Engagement Letter.

    • Cookie Policy means the GSM cookie policy, as set out at Part III below.

    • Data Protection Legislation means the Data Protection Act 2018 and the General Data Protection Regulation (EU) 2016/679 (GDPR) or its successor or equivalent.

    • Engagement Letter means any letter issued to you by us confirming that we will provide the Services to you in accordance with its terms and with these Terms of Business.

    • Privacy Policy means the GSM privacy policy, as set out at Part II below.

    • Services means the consultancy and other services provided by us to you in accordance with your instructions or the instructions of those authorised by you and/or any scope of works agreed between us, as may be more specifically set out in the Engagement Letter or otherwise agreed with you.

  2. Basis of this Agreement and Services

    We will provide you with an Engagement Letter setting out the Services to be provided to you. Any changes or addition to the Services will be agreed with you in writing, which may be by email. In the event of any conflict between any Engagement Letter and the Terms of Business, the Engagement Letter shall prevail.

  3. Conflict of Interest/Confidentiality

    We will endeavour to establish at the outset that no conflict of interest exists. If you have any reason to think one may exist, please advise us in writing as soon as is reasonably practicable. We will not take on work adverse to you, or for a party who we have previously been adverse to on your behalf, without first discussing it with you.

    It is our policy to treat all your information and documents as confidential and to protect such documents from disclosure to other customers and third parties. However, in providing Services to you it may be necessary for us to disclose some information as set out in paragraph 6. below and you agree to the disclosure by us of this information for such purposes.

  4. Fees/Estimate

    You will be billed for the Services in accordance with the fee rates set out in the Engagement Letter or as otherwise expressly agreed between us in writing. Any changes to fee rates will be agreed in writing and will take effect from the agreed date.

    Any expenses that you agree to reimburse, including without limitation, for couriers, travel expenses, mileage, hotels, subsistence costs and/or any other costs/disbursements, will be charged to you at cost (with VAT where applicable).

    Our goal is to deliver value for the fees paid. If ever you think this is not the case, please discuss it with us.

  5. Payment terms

    We will invoice on a monthly basis for Services incurred during that month, unless otherwise set out in the Engagement Letter. Invoices issued by us are due for payment upon receipt. We reserve the right to charge interest at 4% over the base rate of the Bank of England, or such higher rate as is allowed by statute, on all undisputed sums outstanding in excess of 30 days from the date of issue.

    Any payments or bank transfers that incur bank charges from your bank are your responsibility. You should check what these charges are and add them to the amount you transfer. If you do not, we reserve the right to include these charges on our invoices to you.

    We reserve the right to suspend and/or terminate provision of the Services should fees remain outstanding over 60 days. We will tell you if we decide to suspend and/or terminate our Services in these circumstances. If we terminate the Services for any reason, the fees and expenses incurred up to that date and remaining unbilled will then be invoiced to you.

  6. Data Protection

    1. Data Protection Legislation requires us to advise you that your particulars are held on our devices and technology systems. You agree that we may from time to time use these details to provide you with information (whether by email or otherwise) that we think might be of interest to you.

    2. Personal data, information and documents (Information) which you provide to us or which we otherwise handle in relation to you may be both confidential and subject to the Data Protection Legislation. Unless otherwise defined herein, definitions used in this paragraph shall have the same meanings as those used in the Data Protection Legislation.

    3. In providing Services to you it may be necessary for us to disclose some of this Information (including Customer information as described in paragraph 3) to third parties, for example to other professional advisers, our accountants, regulators and insurers, as well as to government agencies. We may also be required to disclose such Information by law or court order. You agree to the disclosure by us of this Information for such purposes.

    4. If stated in the Engagement Letter, we may from time to time make reference to you being a client of GSM, both orally an in print (e.g. on our Site). If consent for this has been given, you can withdraw that consent at any time and all references will cease.

    5. You acknowledge that we may process personal data provided by you to provide the Services. Information regarding GSM’s obligations as a ‘data controller’ and your rights as a data subject are set out in the Privacy Policy and Cookie Policy, which are incorporated herein.

    6. For personal data that we process under your instructions, we are a ‘data processor’, and you hereby confirm that you have all necessary appropriate consents and notices in place to enable lawful transfer of such personal data to GSM. We will not access or use such personal data except as necessary to maintain or provide the Services, or as necessary to comply with the law or a binding governmental order. We will, at your cost, assist you in responding to any request from one of your data subjects and help you comply with your obligations under Data Protection Legislation with respect to security, breach notifications, impact assessments and consultations with supervisory authorities or regulators.

    7. Further, we:

      1. confirm that we have appropriate technical and organisational measures in place to protect against unauthorised and/or unlawful access to or processing of personal data and against accidental loss or destruction of, or damage to, personal data, appropriate to the harm that might result from the unauthorised or unlawful processing or accidental loss, destruction or damage and the nature of the data to be protected, having regard to the state of technological development and the cost of implementing any measures;

      2. confirm that if we become aware of any accidental, unauthorised or unlawful destruction, loss, alteration, or disclosure of, or access to your personal data (Security Incident), we will notify you as soon as is reasonably practicable and provide you with details of the Security Incident and the identity of each affected data subject (if possible) together with any other information you may reasonably request in relation to such Security Incident;

      3. will ensure (via contractual obligations and internal policies) that GSM staff authorised to process your personal data will protect it in accordance with GSM's legal obligations;

      4. confirm that if you send us a written request for a copy of your personal data, we will use reasonable endeavours to provide that copy to you within 10 business days (unless it has been removed/ deleted);

      5. agree not to transfer personal data outside the UK or EEA (to the extent the UK is not in the EEA) unless we have complied with our obligations under Data Protection Legislation in ensuring adequate safeguards in relation to such transfer; and

      6. will maintain records and information to demonstrate compliance with this paragraph and allow for audits by you (or your designated auditor) solely for the purpose of checking compliance with this paragraph, provided that we are given reasonable notice of such audit, such audit is conducted in a manner so as not to interfere with GSM's day to day business operations, such audit is at your cost, and you are not in breach of Data Protection Legislation.

      7. You understand and agree that we may engage third parties (sub-processors) to process your personal data provided that:

        1. each sub-processor is subject to appropriate data protection terms that require it to protect your personal data to the standard required by Data Protection Legislation; and

        2. we remain liable for any breach of this Agreement that is caused by an act, error or omission of any of our sub-processors.

      8. You further understand and agree that we may keep your personal data on devices and technology systems after termination of this Agreement until you ask in writing for it to be deleted or removed. In which case we will do so to the extent reasonably practicable, or unless we are required to keep it by law or have a legitimate interest to keep it, for example, for liability and/or insurance purposes.

  7. Communication by email

    We usually communicate by email and you consent to us sending and receiving emails to/ from you and relevant third parties in relation to the Services (unless otherwise communicated to GSM in writing). You understand and accept that communication by email may not be secure or error free. Emails and their attachments may be delayed, corrupted, intercepted, changed or otherwise lost for reasons outside our control. We shall not be responsible for any loss or claim arising out of or in accordance with the sending or receipt of e-mails and attachments whether by you, us or any third party in connection with this engagement except to the extent that any losses or claim are caused by our negligence or wilful default.

  8. Force Majeure

    In these Terms of Business, Force Majeure Event shall mean any cause, event or contingency beyond our reasonable control including but not limited to acts of God, outbreaks of hostilities, riots, civil disturbances, fire, explosion, flood or severe weather, power failure, failure of telecommunications lines (including IT/data links), theft, and/or malicious damage.

    If we are prevented or delayed in carrying out any of our obligations under any engagement by a Force Majeure Event we shall use all reasonable endeavours to mitigate the effects of such Force Majeure Event but we shall not be under any liability to you for any losses howsoever caused as a result of such Force Majeure Event.

  9. Limitation of Liability

    1. The aggregate liability of GSM, its directors, partners, consultants, agents, sub-contractors and employees for all losses, including without limitation for negligence, breach of contract, misrepresentation or otherwise on its or their part in relation to any Services we perform under this Agreement shall not exceed the amount of fees paid by you to us. GSM is a limited liability company and does not have professional indemnity insurance.

    2. Subject to paragraph 9.v below, all liability of GSM for the following is hereby excluded:

      1. any loss or damage which does not arise as a direct and natural consequence of the default in question, including indirect, special, exemplary, punitive or consequential loss or damage;

      2. loss of profits, anticipated savings, revenue or business

      in each case whether arising from negligence, breach of contract or otherwise, even if we have been advised of the possibility of such loss or damage arising.

    3. Unless we agree otherwise and so consent in writing, the Services are provided to the customer with whom we have entered into an Engagement Letter of which these Terms of Business form part and we shall be under no liability to any third party (including but not limited to any of your affiliates) in respect of the Services provided to you.

    4. Except as set out in these Terms of Business, all warranties, representations, conditions and other terms implied by statute or common law are, to the fullest extent permitted by law, excluded.

    5. Nothing in this Agreement excludes or limits in any way whatsoever the liability of GSM or its directors, consultants, agents, sub-contractors and employees for:

      1. death or personal injury caused by the negligence of GSM, its directors, consultants, agents, sub-contractors or employees; or

      2. fraud or fraudulent misrepresentation; or

      3. any other liability that cannot be excluded or limited by law.

  10. Miscellaneous

    1. These Terms of Business apply to any Services performed by GSM, subject to any variation agreed between the parties in any Engagement Letter or otherwise.

    2. A person who is not a party to the engagement shall have no rights (whether under the Contracts (Rights of Third Parties) Act 1999 or otherwise) to enforce any of its terms.

    3. All advice, documentation, etc. that we provide to you is for your sole use and must not be communicated to any third party save as permitted by GSM in the course of rendering the Services. We accept no responsibility to any third party for any aspect of our Services or work.

    4. This Agreement sets forth the entire agreement between the parties and supersedes all prior oral or written agreements, understandings or arrangements relating to the subject matters hereof. Neither party shall be entitled to rely on any prior agreement, understanding or arrangement that is not expressly set out or incorporated by reference therein.

    5. The parties to this Agreement are independent contractors. Nothing in this Agreement is intended to, or shall be deemed to, constitute a partnership, joint venture or employment relationship of any kind between the parties, nor constitute any party an employee or the agent of another party for any purpose. No party shall have authority to act as employee or agent for the other party in any way, unless otherwise agreed in writing.

  11. Term and Termination

    1. This Agreement commences on the date of the Engagement Letter or the date on which you first instruct us to provide Services, whichever is earlier. You acknowledge that you accept the terms of this Agreement by signing and returning a copy of the Engagement Letter or by otherwise instructing GSM to provide Services to you. The terms of this Agreement apply retrospectively to any Services provided prior to your acceptance of their terms.

    2. Either party may, by written notice, terminate the Services with immediate effect by giving written notice to the other or as otherwise specified in the Engagement Letter. Upon termination of the Services for any reason, all fees and expenses incurred up to the date of termination and remaining unbilled will be immediately due and payable.

    3. Any provisions of this Agreement which expressly or by implication are intended to continue in force after termination shall remain in full force and effect.

  12. Governing law and Jurisdiction

    This Agreement shall be governed by English Law and the parties agree to submit to the exclusive jurisdiction of the English Courts.

II. Privacy Policy

Protecting personal data is a priority. This policy tells you the types of information we collect when you visit our website and/or use our services, how we use that information, and when we may share that information. This policy may change from time to time so please check it every so often. The date that it comes into effect is at the end.

For the purposes of this Privacy Policy, the term “personal data” means any information which identifies a person or which allows that person to be identified when combined with other information.

  1. Who we are

    This Privacy Policy applies to the website at www.greysealmedia.com (the “Site”) and services provided by Grey Seal Media Limited (GSM, we, us, or our), registered in England with number 12578064 and with its registered office at 27 Old Gloucester Street, London, WC1N 3AX. GSM is a “data controller” for some data and a data processor for others. We are responsible for the Site and the provision of our services and the personal data collected from it.

    If you have any questions about this, including any requests to exercise your legal rights, please contact us at our address or at clare@greysealmedia.com.

  2. Data we collect

    We collect and use personal data to operate our Site and to deliver services, as well as to provide useful updates and other information about our services. Further information about this is below. In this context, we are a “data controller”.

    If you are using our services, it may be necessary or useful for you to provide certain personal data to us, for example, about customers, staff, suppliers, etc. In this context, you are the “data controller” and we are your “data processor“. You must therefore ensure you are lawfully permitted to transfer such personal data to us. We will only use the data to provide the services or as necessary to comply with applicable laws.

    We may collect, use, store and transfer different kinds of personal data which we have grouped together as follows:

    • Identity data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth, gender, and social media accounts.

    • Contact data includes billing address, delivery address, email address and telephone numbers.

    • Financial data includes bank account and payment card details.

    • Transaction data includes details about payments made and other details of goods and/or services purchased.

    • Technical data includes information about use of a website, internet protocol (IP) address, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology used to access websites.

    • Profile data includes usernames and passwords, purchases or orders made, preferences, feedback and survey responses.

    • Marketing and communications data includes preferences in receiving marketing from us and third parties and communication preferences.

    • Employment data includes current and past employment, experience, qualifications, skills, interests and any other information disclosed by you.

    We may also collect, use and share Aggregated Data such as statistical or demographic data. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. 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.

    It is unlikely, but possible that in the course of providing services we may also collect special categories of personal data (such as race, ethnicity, religious or philosophical beliefs, sexual orientation, political opinions, trade union membership, information about health, and information about criminal convictions and offences).

  3. How is personal data collected?

    We use different methods to collect data including through:

    Direct interactions

    You may give us details such as a name, email address and other contact details in person, or by filling in forms on our Site or by corresponding with us by post, phone, email, social media and/or otherwise. This includes personal data provided when you:

    • request our services;

    • meet with or contact one of our staff;

    • are introduced to one of our staff by another contact;

    • participate in an event which we have attended or organised;

    • contact us via our Site;

    • subscribe to our publications or newsletters;

    • request information about our services or other information or for materials to be sent to you;

    • respond to a survey;

    • contact us about a role;

    • make a complaint or give us some feedback.

    Automated technologies or interactions

    If you interact with our Site, we may automatically collect technical data about equipment, IP address, browsing actions and patterns. We collect this data by using cookies and other similar technologies. We may also receive technical data if you visit other websites employing our cookies. Please see our Cookie Policy below for further details.

    Third parties and publicly available sources

    We may receive personal data from various third parties as set out below:

    • technical data from analytics providers and/or search information providers; and

    • employment, identity and contact data from recruitment agencies, previous employers, etc.

  4. How we use personal data

    We will only use personal data as permitted by law. Most commonly, we will use personal data in the following circumstances:

    • Where we need to provide services (i.e. because we are contractually obliged to do so).

    • Where it is in our legitimate interest to do so (or those of a third party) and your interests and fundamental rights do not override those interests.

    • Where we need to comply with a legal or regulatory obligation.

    Generally, we do not rely on consent as a legal basis for processing personal data other than in relation to sending useful information and marketing communications to you via telephone and/or email. You have the right to withdraw consent to us contacting you like this at any time by responding to the person that contacts you and/or by contacting us via the details given above.

    We have set out below the ways we use personal data and the legal basis for doing so. We have also identified what our legitimate interest is, where appropriate.

    Purpose/Activity Type of data Lawful basis for processing including basis of legitimate interest

    To register you as a new or prospective customer
    1. Identity
    2. Contact
    1. Performance of a contract with you
    2. Necessary for our legitimate interest (for running our business and to provide our services)

    To process and deliver services to you including:

    1. Manage payments, fees and charges
    2. Collect and recover money owed to us
    1. Identity
    2. Contact
    3. Financial
    4. Transaction
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary for our legitimate interests (to recover any debt due to us)

    To manage our relationship with you, which may include

    • Notifying you about changes to our Terms of Business or privacy policy
    • Asking you for a testimonial or feedback or to take a survey
    1. Identity
    2. Contact
    3. Profile
    4. Transaction
    5. Marketing and Communications
    1. Performance of a contract with you
    2. Necessary to comply with a legal obligation
    3. Necessary for our legitimate interests (to study how customers use our products/services, to develop them and grow our business)

    To administer and protect our business and Site (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)
    1. Identity
    2. Contact
    3. Technical
    1. 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)
    2. Necessary to comply with a legal obligation

    To deliver relevant content and measure or understand the effectiveness of the such content
    1. Identity
    2. Contact
    3. Profile
    4. Technical
    5. Marketing and Communications

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

    To use data analytics to improve our Site, services, marketing and customer relationships and experiences
    1. Technical

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

    To make suggestions and recommendations to you about goods or services that may be of interest to you
    1. Identity
    2. Contact
    3. Technical
    4. Profile

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

    We may process personal data for more than one lawful ground depending on the specific purpose for which we are using data. Please contact us if you want further details about the specific legal ground we are relying on to process your personal data.

    Where we need to collect personal data by law, or under the terms of a contract and you do not provide that data when requested, we may not be able to perform the contract. In this case, we may have to cancel a service you have with us but we will notify you of this at the time.

    Newsletters and marketing communications

    You may receive newsletters, updates, news and information about our services and/or other marketing communications from us if you have requested such information from us, purchased our services or if you provided us with your details when you contacted or registered with us unless you told us you did not want to receive such information.

    We may also inform you of products or services available from carefully selected partners.

    We may also contact you via surveys to conduct research about your opinion of our services.

    We do not give or provide in any other way customer lists to third parties.

    Opt-out or unsubscribe

    We respect your privacy. You may, at any time opt-out of receiving certain types or all communications from us by contacting us (as set out above) or selecting the “unsubscribe” option in any e-communication from us.

    Cookies

    Our Site may use cookies and similar technologies to distinguish you from other users of our Site. This helps us to provide you with a good experience when you browse our Site and allows us to improve our Site.

    You can set your browser to refuse all or some browser cookies. For more information about the cookies we use, please see our Cookie Policy below.

    Third-party links and services

    Our Site may include links to third-party websites and/or plug-ins. 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 or services and are not responsible for their privacy practices or privacy statements. When you leave our Site, we encourage you to read the privacy policy of any new website you visit if this a concern for you.

    Children

    The Site and our services are not intended for children and we do not knowingly collect data relating to children.

  5. How we may share personal data

    We may have to share personal data with third parties as per below for the purposes set out in the table above:

    • Service providers who perform services and functions on our behalf in connection with the operation of our business such as software and application service providers, third parties who host, store and manage data or provide programming or technical support, etc.

    • Professional advisers including our accountants, insurers and brokers, etc.

    • Analytics partners to analyse Site traffic and understand customer needs and trends.

    • Marketing service providers to help us to communicate with you.

    • If we are required to do so by law, or if we believe that such action is necessary to: (a) fulfil a government, or regulatory authority request; (b) conform with the requirements of the law or legal process; (c) protect or defend our legal rights or property, our Site or customers.

    • Those to whom we may sell, transfer, or merge parts of our business with, or where we acquire other businesses or merge with them. If such a change happens then any new owners may use your personal data in the same way as set out in this policy.

    We require third parties to respect the security and confidentiality of personal data and to treat it in accordance with the law. We do not allow third-party service providers to use personal data for their own purposes and only permit them to process personal data for specified purposes and in accordance with our instructions.

    We will disclose personal information, without notice, only if required to do so by law or in the good faith belief that such action is necessary to:

    • comply with legislation or legal process served on us;

    • protect and defend our rights and/or property; and

    • to protect personal safety.

  6. International transfers

    Our third-party service providers may be based outside the European Economic Area (EEA) and when they are their processing of personal data will involve a transfer of data outside the EEA.

    Whenever we transfer personal data out of the EEA or UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

    • We will only transfer personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

    • Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

    • Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.

  7. Security of your personal data

    We have put in place appropriate security measures to prevent personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to personal data to those of our staff and other third parties who have a business need to know. They will only process 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.

  8. Data retention

    We will retain personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

    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 personal data, the purposes for which we process personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

    For example, if you are a client, we will generally keep your personal data for the longer of six years from the date of the last interaction with you or until the applicable statutory limitations period has expired.

    We regularly review the personal data we hold taking into account the lawful purpose for which we hold it and any data that is deemed no-longer relevant or required is deleted where it is practicable to do so

  9. Your legal rights

    You have the right to:

    • Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are processing it lawfully.

    • Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    • Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    • Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. It is unlikely, but in some cases we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    • Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    • Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    • Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

    No fee usually required

    You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

    What we may need from you

    We may need to request specific information from you to help us confirm your identity and ensure your right to access personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who does not have a right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

    Time limit to respond

    We try to respond to all legitimate requests as soon as reasonably practicable and at least within one month. Occasionally it may take us longer if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

III. Cookie Policy

The Grey Seal Media website at www.greysealmedia.com (the “Site”) may use “cookies” to help you personalize your online experience and to help us to distinguish you from other users. If cookies are in use, when you use our Site for the first time you will be given the opportunity to accept or decline cookies. By accepting the cookies, you agree to our use of the cookies as set out in this policy.

What is a cookie?

A cookie is a piece of data sent to your device from a website which is stored on your browser or the hard drive of your computer if you agree. A cookie is a text file that is placed on your hard disk by a web page server.

Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

Cookies used on our Site

The exact names of cookies we use on our Site may change from time to time, however, the descriptions below set out the types of cookies that operate on our Site. You can obtain an up to date list of the cookies we use by contacting us clare@greysealmedia.com.

  • Strictly necessary cookies. These are cookies that are required for the operation of our Site. They include cookies used to recognise you when you return to our Site so we remember your preferences (for example, our newsletter pop-up that logs the date it will next show for the visitor).

  • Analytical/performance cookies. They allow us to recognise and count the number of visitors and to see how visitors move around our Site when they are using it. This helps us to improve the way our Site works, for example, by ensuring that users are finding what they are looking for easily.

Google Analytics

We may use Google Analytics. The information generated by the Google Analytics cookie (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Service, compiling reports on activity and providing other services relating to activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where third parties process the information on Google’s behalf.

To see more information on the cookies set by Google Analytics see: Cookies and Google Analytics. To opt out of being tracked by Google Analytics across the Site visit https://tools.google.com/dlpage/gaoptout

We may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs on our Site and in emails, for example, to determine whether a recipient opened the email or accessed a certain link.

How to delete or change your cookies preferences

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. You can also set your browser to alert you when a website sets or accesses cookies. The ‘Help’ function within your browser should tell you how to do this.

Alternatively, you may wish to visit www.aboutcookies.org which contains comprehensive information on how to do this on a wide variety of browsers. You will also find details on how to delete cookies from your machine as well as more general information about cookies

Please be aware that restricting cookies may impact on the functionality of our Site.