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Data Retention Policy

Effective from 19th February 2023

Introduction

WOW Media UK Ltd retains personal data as outlined on our various privacy policies across our websites, you can find a link to the privacy policy for the relevant website in the footer of the website. In retaining such data, WOW Media UK Ltd must comply with the Data Protection Act 1998 and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any new or updated legislation that is in existence at the relevant time (“the Legislation”).

In compliance with the Legislation, WOW Media UK Ltd have prepared this policy to set out the principles for the retention and destruction of data that is supplied by consumers and businesses (affiliates and advertisers). This policy covers all employees (whether full time or not) and all directors and officers of WOW Media UK Ltd, wherever they may be located or working. WOW Media UK Ltd also expects its consultants and goods and service providers to introduce and follow appropriate data retention and destruction practices.

This policy covers all data retained or in WOW Media UK Ltd’s custody or control in whatever medium such data is contained in. This policy is not therefore restricted to information contained in paper documents but includes data contained in an electronically readable format.

This policy should be read in conjunction with WOW Media UK Ltd’s Privacy Policies as outlined above.

Objectives

In addition to compliance with the Legislation, WOW Media UK Ltd may be involved in unpredicted events such as litigation or business disaster recoveries that requires us to have access to the data in order to protect WOW Media UK Ltd’s interests or those of our employees, customers, good and services providers and our partners.

As a result, data may need to be archived and stored for longer than the data may be needed for day to day operations and business processes.

Broadly, when WOW Media UK Ltd’s data retention period is over and we no longer need the data, we ought to destroy it in a proper manner.

Retention policy

Retention is defined as the maintenance of documents in a production or live environment which can be accessed by an authorised user in the ordinary course of business.

Broadly the data that WOW Media UK Ltd stores is as follows:

  1. Consumers and Businesses relating to the websites wowfreebies.com, wowvouchercodes.com, wowtrk.com and wowmedia.net:

    name, email address, IP address, connection information (browser type and version, operating system and platform, reference number linked to the data, login details, URL clickstream to, through and from WOW Media UK Ltd’s site including date and time), cookie number, activity on WOW Media UK Ltd’s website including pages visited and searches made, phone number (if they contact us by phone) and any emails received and sent to WOW Media UK Ltd;

  2. Affiliates and Advertisers relating to the website affiliates.wowmedia.net:

    business entity name, individual title, personal and / or business entity related e-mail address, mailing address, daytime and/or cellular telephone numbers, fax number, account information (or other information that WOW Media UK Ltd require in order to pay any amounts due to the affiliate under the Affiliate Network) and/or any other information requested on the applicable Subscriber registration form, type of browser, operating system, IP address, and any emails received and sent to WOW Media UK Ltd.

  3. Visitors of Affiliates websites registered on affiliates.wowmedia.net:

    IP address, type of browser, mobile device data (device information including mobile device identifiers), referral URL and any information the Affiliate may choose to pass to us in Sub ID, Click ID, Unique ID and Source data fields (although they are required not to pass any Personal Data, they may do so as this is outside of our control). We may also collect further Personal Data about Visitors for investigating invalid or untracked Events if the Affiliate chooses to send us information about these Events and includes Personal Data. Further information about this can be found in the Privacy Policy for wowmedia.net

  4. Visitors of Advertisers websites registered on affiliates.wowmedia.net:

    We don’t automatically collect any Personal Data about our Advertisers Visitors however Advertisers may choose to pass Personal Data to us in affiliate tracking codes. Personal Data Advertisers may pass back to us could include (but not limited to); IP address, type of browser, Mobile Device data and Customer Name. We may also collect further Personal Data about Visitors for investigating invalid or untracked Events if the Advertiser chooses to send us information about these Events and includes Personal Data.

  5. Employees and Contractors of WOW Media UK Ltd:

    The information we collect about employees and contractors is detailed in the ‘Privacy Notice to Staff’ document.

The above data must only be stored so long as it is necessary.

WOW Media UK Ltd stores Data in the following places, not all types of Personal Data is stored in all places listed below.

  1. Internal Databases on our Cloudways Servers - Our Cloudways servers host some of our websites and some of our website internal databases. Personal Data will remain within these databases for as long as necessary and to comply with legal requirements. Some Personal Data is synced from Bigin, MailerLite and Sendinblue, data will be held within our database for as long as it is on these third party platforms, see below for the retention period for these platforms.
  2. Todoist by Doist (Task Management) - Todoist is used to manage employee tasks and to discuss any tasks that may need to be completed. Tasks may relate to a specific Users account and/or contain Personal Data. Tasks remain on the system for the life of our account so we can review our work history at any time.
  3. G Suite (Email, Drive, Office Suite, Chat, Calendar & more) - We use G Suite for all @wowmedia.net email accounts, managing files (documents, spreadsheets, PDF setc), internal communication using Hangouts Chat, managing meetings and appointments using calendar. If we send an email or an email is sent to us this may remain within Gmail for up to 7 years after which time it will be automatically deleted. Files are kept for as long as necessary and to comply with legal requirements where applicable. File storage is used to store some website back ups. Retention periods will vary depending on the type of file and what it relates to. Hangouts Chat is used to discuss day to day work and potentially about specific Users, messages are kept for 1 year.
  4. Superhuman (Email & Calendar) - Some employees at WOW Media use the Superhuman email client to make managing their email and calendar easier and faster. Superhuman retains data about emails and calendars for as long as required to provide the service, they sync data from G Suite (mentioned above) so data retention will be similar to G Suite however Superhuman retains their own copies and backups for 14 days. You can find out more about how Superhuman handles data retention and privacy here.
  5. pCloud (File Management & Backup Storage) - We use pCloud to store company documents in the cloud, pCloud is also used to store back ups for website content. Any databases that contain personal information are stored using encryption on pCloud. Files are kept for as long as necessary and to comply with legal requirements where applicable.
  6. Groove (Emails) - Groove is an online help desk platform. Emails sent to certain email accounts are automatically forwarded into our Groove account. Groove does not have any automatic retention functionality, however once per year we will be requesting Groove's team to delete any emails received or sent that are older than 7 years.
  7. Postmark (Email Service Provider) - Postmark collects and retains the content and metadata for all emails for 45 days. For bounce reports the original email is removed after 45 days but the metadata and the content of the bounce message is retained for up to 1 year. You can see more about Postmark's data retention policy here. Postmark retains certain data indefinitely to ensure we don't send to users again that may have unsubscribed, complained or hard bounced.
  8. SendinBlue (Email Service Provider) - SendinBlue is used to send out newsletters to subscribers. SendinBlue retains information about subscribers indefinitely, however we will be requesting once per year any subscriber that has either chosen to be unsubscribed or we have chosen to unsubscribe/remove from the list and has been unsubscribed/removed for over 7 years, to be deleted.
  9. MailGun (Email Service Provider) - MailGun is used to process the sending and receiving of some of our emails. Mailgun stores the bodies of messages for up to 72 hours for both incoming and outgoing messages. The metadata of a message, which includes the sender, recipient(s), subject line, originating IP address and other routing data is indexed and maintained for 30 days. Suppressions are permanently stored email addresses that are created as a result of a hard bounce, complaint, or unsubscribe.
  10. MailerLite (Email Service Provider) - MailerLite is used to send out newsletters to subscribers. Twice per year we will review subscribers to the lists held within MailerLite, if a subscriber has been a subscriber for at least 12 months and has not opened an email for 12 months they will be removed from the list. If a subscriber continues to open emails they will remain on MailerLite until such time that they stop opening emails for a period greater than 12 months. Subscriber information will remain on MailerLite to ensure they are not emailed again in the future.
  11. Wise (Payment Processor) - Wise is a service used to send and receive international payments. Wise will retain transactional data for a period of up to 6 years. You can see more about Wise’s retention policy here.
  12. Stripe (Payment Processor) - Stripe is a service used to process payments. Stripe will store Data based on the retention period set out within their Privacy Policy and the agreed Data Protection Addendum. You can see Stripe’s privacy policy here.
  13. PayPal (Payment Processor) - PayPal is a service used to process payments. PayPal will store Data based on legal requirements and PayPal’s internal retention policies. You can see more about how PayPal deals with privacy here.
  14. Google Analytics (Analytical Data) - Google Analytics is used to monitor website traffic and activity on the website. User and event data is retained for 2 months however the retention period is reset for the user identifier with each new event from that user (thus setting the expiration date to current time plus retention period).
  15. Xero (Accounting Platform) - Xero is used for accounting and some aspects of WOW Media UK Ltd’s payroll. Data is kept on the platform in accordance with their data retention policies and procedures.
  16. Yay.com (VoIP Provider) - Yay.com is a hosted VoIP service. Call history will be retained for up to 7 years. Voicemails will be purged from the Yay.com platform at least yearly however a copy of all voicemails are forwarded into Groove, voicemails are retained within Groove for the retention period mentioned for Groove.
  17. CloudFlare (DNS, Security, CDN) - CloudFlare offers CDN, DNS, DDoS protection and security. We use multiple features from CloudFlare including their security features. Personal Data is stored in CloudFlare’s error logs for 24 hours. IP Addresses are also stored in the CloudFlare Firewall for blocking suspect traffic for security reasons, some IPs are also whitelisted if they are having issues connecting to our websites, these IPs are stored indefinitely for security and access purposes.
  18. EWWW IO (CDN) - EWWW provides image optimization and a CDN service for some of our websites. EWWW collects users IP addresses but only stores an anonymised version of the IP addresses. Further Personal Data may be passed through URL queries. ShortPixel and their partners will keep this information as long as required. More about how EWWW handles privacy can be found here.
  19. ShortPixel (CDN) - ShortPixel provides image optimization and a CDN service for some of our websites. Personal Data could be stored within ShortPixel or ShortPixel’s partners logs. IP addresses and device information are most likely to be stored. IP addresses are anonymised. Further Personal Data may be passed through URL queries. ShortPixel and their partners will keep this information as long as required.
  20. SignNow (E-Signature Service) - SignNow is an electronic signature service used to sign documents electronically and also to store agreements/contracts. Documents are stored on the service for 7 years, unless we request otherwise, for example a document may need to be kept longer for legal or compliance reasons. You can read more about how this is handled on SignNow’s website here.
  21. Signaturely (E-Signature Service) - Signaturely is an electronic signature service used to sign documents electronically and also to store agreements/contracts. Documents are stored on the service until our account with Signaturely is closed, unless we request otherwise. More about how Signaturely handles privacy can be found here.
  22. Automattic Inc’s Jetpack, WordAds, Vaultpress & Akismet services (Website security, speed, spam protection, ad service, backup services and more, detailed at Jetpack.com) - We use the Jetpack plugin by Wordpress on some of our websites for additional website features and for security. You can find out about the retention periods for the Jetpack plugin here. The Jetpack plugin also uses the Vaultpress and Akismet services for back ups and spam protection. You can find out more about privacy at Automattic Inc on their privacy policy here. Also how Akismet deals with the GDPR here.
  23. GoodBarber (Native App Builder) - We use Goodbarber to manage our app for the WOW Freebies website. GoodBarber may store Personal Data about Users for as long as is necessary to provide the services within the App to the User.
  24. Skimlinks (Advertising) - We use Skimlinks to automatically create affiliate links on our website content. Skimlinks may store data about a User for up to 3 years.
  25. MailChimp (Email Service Provider) - MailChimp is used to send out newsletters to subscribers. MailChimp retains records for the life of our account. If a user unsubscribes we will still retain the data so as we know the user has unsubscribed and don't accidentally subscribe them again. Once per year we will review subscribers to the lists held within MailChimp, if a subscriber that joined more than 12 months ago has not opened any of our recent email campaigns they will be unsubscribed from the list but their data will still be kept on the system unless the user requests for their data to be removed. More about MailChimp's privacy can be found on their privacy policy here.
  26. Make.com (Automation tool) - Make.com is a tool to help automate processes between online tools and platforms. Make.com varies depending on automation settings but can be up to 60 days for automation logs which may include user details. You can find out more details about privacy and data retention at Make.com here. Due to the nature of the Make.com platform retention periods may change frequently but systems are always designed with keeping in mind that data should not be stored longer than required.
  27. Sunsama (Day Planner/Task Management) - Sunsama is used to manage employee tasks and to plan out specific days work. Tasks may relate to a specific Users account and/or contain Personal Data. Tasks remain on the system for the life of our account so we can review our work history at any time. Further information about Sunsama’s privacy can be found here.
  28. Notion (Workspace Tool) - Notion is an all in one workspace tool, it blends task management, databases, project tracking and more. We use Notion for multiple purposes which changes over time but can include storing customer information and leads. Information remains on Notion indefinitely, if we choose to fully delete data from Notion it is removed entirely after 30 days. Further information about Notion’s privacy can be found here.
  29. Bigin by Zoho CRM (CRM) - Bigin is a customer relationship management tool that is used to manage sales leads and customer data of the wowtrk.com website and platform. Information about leads and customers remains on Bigin indefinitely in order to effectively manage sales and customers. Individual Personal Data can be removed on request and will be fully deleted after 60 days of being deleted. Further information about Bigin’s privacy can be found here.
  30. Jivochat (Live Chat Software) - Jivochat provides us with live chat software for our websites and to manage communication across social media channels. Conversations stored within Jivochat are kept for up to 2 years. You can find out more about privacy at Jivochat here.
  31. Calendar Hero (Calendar Scheduling) - Calendar Hero provides software for WOW Media employees to simplify scheduling meetings and phone calls with existing and new clients. Calendar Hero will retain information provided for meeting scheduling for the life of our account. Individual Personal Data can be removed on request. You can find out more about privacy at Calendar Hero here.
  32. Deputy (Workforce Management) - Deputy provides a tool to manage employees information and the ability to track how many hours employees have worked. Data remains on Deputy indefinitely. You can find out more about privacy at Deputy here.
  33. Scaleo (Affiliate Management Platform) - Scaleo provides a platform for us to manage affiliate partners we work with and to automatically record information about their end users when they go through a tracking platform by our Scaleo instance. Information about clicks and conversions that affiliate partners send through our tracking links is kept for 12 months. We obfuscate IPs when recording conversions in order to minimize the amount of PII that is kept. You can find out more about privacy at Scaleo here.

The periods referred to in the sections above apply unless an exception has been obtained permitting a longer or shorter active use period by WOW Media UK Ltd.

After active use has expired, and according to appropriate exceptions, data shall be archived in accordance with section D until the data is destroyed in accordance with section E.

Matthew Lovett shall be responsible for enforcing the retention and destruction of data and communicating these periods to the relevant employees.

Matthew Lovett is also responsible for submitting exception requests to the process, including consulting and receiving legal advice if necessary to justify making an exception request under section E.

Destruction Policy

Destruction is defined as physical or technical destruction sufficient to render the information contained in the document irretrievable by ordinary commercial means.

The data that is held by WOW Media UK Ltd is done so on  an electronic database In order for successful destruction to take place therefore, WOW Media UK Ltd do so by reviewing the database and deleting the information.

Exceptions to the retention period

Matthew Lovett shall be responsible for determining if the retention or destruction of data should fall outside the policies as outlined above. No data should be retained or destroyed in a manner that falls outside of these policies without the authorisation of Matthew Lovett.

WOW Media UK Ltd shall also retain data for affiliates whose accounts have been suspended for a period of six years. The purpose of retaining such data is in the event that a dispute or potential legal issue occurs which will require evidence.

Enforcement and reporting breaches

Breaches of this policy may have serious legal and reputational repercussions and could cause material damage to WOW Media UK Ltd.  Consequently, breaches can potentially lead to disciplinary action that could include summary dismissal for gross misconduct.

All employees are expected to promptly and fully report any breaches of this policy.  A report may be made to that employee’s supervisor or Matthew Lovett.  Reports made in good faith by someone who has not breached this policy will not reflect badly on that person or their career at WOW Media UK Ltd. Reports may also be made to the following email address: matt@wowmedia.net.