By entering the competition you agree that you are over 18 years of age, have a valid passport and

that you have

read and agreed to the below Terms and Conditions.

1. The Promoter

The promoter is: PUBITY GROUP LTD of 20 Dale Street Manchester England M1 1EZ.

2. The competition

2.1 The title of the competition is “One comment with 0 likes wins UEFA Champions League Tickets and Airmiles
from Turkish Airlines.”

3. How to enter

3.1 The competition will run from 00:01 on 08.05.2023 (the "Opening Date") to 23:59 on 14.05.2023 (the "Closing
Date") inclusive.

3.2 All competition entries must be received by the Promoter by no later than 23:59 on the Closing Date. All
competition entries received after the Closing Date are automatically disqualified.

3.3 To enter the competition:

(a) You must comment on the post (unlimited entries) and also follow @turkishairlines by the Closing
Date.

3.4 No purchase necessary and there is no charge to register.

3.5 The Promoter will not accept:

(a) responsibility for competition entries that are lost, mislaid, damaged or delayed in transit, regardless
of cause, including, for example, as a result of any postal failure, equipment failure, technical
malfunction, systems, satellite, network, server, computer hardware or software failure of any kind;
or

(b) proof of posting or transmission as proof of receipt of entry to the competition.

3.6 By submitting a competition entry, you are agreeing to be bound by these terms and conditions.

3.7 Please see www.pubitygroup.com for a copy of these competition terms and conditions.

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3.8 The winner will be picked at random by choosing a comment with 0 likes.. The winner will be informed via
Instagram within 3 days of the Closing Date and must respond within 3 days to claim their prize.

3.9 The name of the winner may be used for publicity purposes.

4. Eligibility

4.1 The competition is only open to all aged 18 years or over with a valid Passport, except:

(a) employees of the Promoter or its holding or subsidiary companies;

(b) employees of agents or suppliers of the Promoter or its holding or subsidiary companies, who are
professionally connected with the competition or its administration; or

(c) members of the immediate families or households of (a) and (b) above.

4.2 In entering the competition, you confirm that you are eligible to do so and eligible to claim the prize. The
Promoter may require you to provide proof that you are eligible to enter the competition.

4.3 The Promoter will not accept competition entries that are:

(a) automatically generated by computer;

(b) completed by third parties or in bulk;

(c) illegible, have been altered, reconstructed, forged or tampered with;

(d) photocopies and not originals; or

(e) incomplete.

4.4 There is no limit of entries to the competition per person. Entries on behalf of another person will not be
accepted and joint submissions are not allowed.

4.5 Entries by those living in countries not covered by Turkish Airlines can choose to fly from any Turkish Airlines
destination country but they are responsible for their own transport to and from the respective country. A list
of Turkish Airlines destinations can be found here: https://www.turkishairlines.com/en-int/flight-destinations/

4.6 The Promoter reserves all rights to disqualify you if your conduct is contrary to the spirit or intention of the
prize competition.

5. The Prize

5.1 The prize available to win is x2 Semi-Final UEFA Champions League Match Tickets to Manchester City FC vs
Real Madrid CF on Wednesday 17th May 2023 and 150,000 airmiles with Turkish Airlines.

5.2 The airmiles are provided by TURKISH AIRLINES. All flights must fly to Istanbul before flying to the relevant
county for the UEFA Champions League Football Match.

5.3 The airmiles are to travel by aeroplane in economy class. The prize does not include travel insurance, the cost
of transfers to and from airports or stations, food and drink, spending money, tax or personal expenses. Any

2
 other costs incurred in addition to /those set out above and that are incidental to the fulfilment of the prize are
the responsibility of the winner(s).

5.4 You will be responsible for ensuring that you and any person travelling with you are available to travel and
hold valid passports, any necessary visas and travel documents for the holiday in question on the travel dates
specified. Dates once notified to Turkish Airways cannot be changed.

5.5 Prizes are subject to availability. There is no cash alternative for the prize. The prize is not negotiable or
transferable.

5.6 Winners are not entitled to a flight on any specific date. Flights are subject to availability and if the requested
flights are not available for the required dates the winners must choose an alternative date and cannot pay
the difference in order to upgrade from economy class.

5.7 The prize is supplied by TURKISH AIRLINES INC. Turkish Airlines General Management Building, Ataturk
Airport, Yesilkoy 34149 Istanbul Türkiye (the "Supplier"). The Promoter reserves the right to replace the prize
with an alternative prize of equal or higher value if circumstances beyond the Promoter's control makes it
necessary to do so.

5.8 In order to claim the prize the winner must respond to the direct message @pubity will send to the Instagram
account used by the winner to enter the competition. The Promoter will provide the winner with an email
address for the relevant contact at the Supplier who once contacted by the winner shall provide the winner
with the prize directly.

6. Winners

6.1 The decision of the winner is final and no correspondence or discussion will be entered into regarding the
decision or appealing the decision.

6.2 The Promoter will contact the winner as soon as practicable after the Announcement Date, using the Instagram
account provided with the competition entry. The Promoter will not amend any contact information once the
competition entry form has been submitted.

6.3 The Promoter must either publish or make available information that indicates that a valid award took place.
To comply with this obligation the Promoter will publish the surname and county of major prize winner and, if
applicable, their winning entry as a story post on @pubity (Announcement Date).

7. Claiming the prize

7.1 If you are the winner of the prize, you will have 3 days from the Announcement Date to claim the prize by
providing your email address and providing the information requested from the Promoter. If you do not claim
the prize by this date, your claim will become invalid.

7.2 The prize may not be claimed by a third party on your behalf.

7.3 The Promoter will make all reasonable efforts to contact the winner. If the winner cannot be contacted or is
not available, or has not claimed their prize within 3 days of the Announcement Date, the Promoter reserves

3
 the right to offer the prize to the next eligible entrant selected from the correct entries that were received before
the Closing Date.

7.4 The Promoter does not accept any responsibility if you are not able to take up the prize.

8. Limitation of liability

Insofar as is permitted by law, the Promoter, its agents or distributors will not in any circumstances be
responsible or liable to compensate the winner or accept any liability for any loss, damage, personal injury or
death occurring as a result of taking up the prize except where it is caused by the negligence of the Promoter,
its agents or distributors or that of their employees. Your statutory rights are not affected.

9. Ownership of competition entries and intellectual property rights

9.1 All competition entries and any accompanying material submitted to the Promoter will become the property of
the Promoter on receipt and will not be returned.

9.2 By submitting your competition entry and any accompanying material, you agree to:

(a) assign to the Promoter all your intellectual property rights with full title guarantee; and

(b) waive all moral rights,

in and to your competition entry and otherwise arising in connection with your entry to which you may now or
at any time in the future be entitled under the Copyright, Designs and Patents Act 1988 as amended from time
to time and under all similar legislation from time to time in force anywhere in the world.

9.3 You agree that the Promoter may, but is not required to, make your entry available on its website
www.pubitygroup.com and any other media, whether now known or invented in the future, and in connection
with any publicity of the competition. If applicable, you agree to grant the Promoter a non-exclusive, worldwide,
irrevocable licence, for the full period of any intellectual property rights in the competition entry and any
accompanying materials, to use, display, publish, transmit, copy, edit, alter, store, re-format and sub-licence
the competition entry and any accompanying materials for such purposes.

10. Data protection and publicity

10.1 The Promoter will only process your personal information as set out in the privacy policy on
www.pubitygroup.com. See also condition 6.3, with regard to the announcement of winner.

11. General

11.1 If there is any reason to believe that there has been a breach of these terms and conditions, the Promoter
may, at its sole discretion, reserve the right to exclude you from participating in the competition.

11.2 The Promoter reserves the right to hold void, suspend, cancel, or amend the prize competition where it
becomes necessary to do so.

11.3 These terms and conditions are governed by English law. If any entrants to this promotion wish to take court
proceedings, then they must do this within the courts in the United Kingdom.

4
PRIVACY POLICY we will collect your input and other participation
information.
Last updated 23 February 2021 • When we send you emails or other
communications or if you interact with our content
This privacy notice explains how we, Pubity Group all over the Internet we may collect engagement
Limited of 20 Dale Street, Manchester, M1 1EZ and our information such as open rates, click rates, view
affiliated companies and other brands (collectively, rates, active time spent and similar information.
“Pubity Group”, “we”, “us”, “our”) process your personal • When accessing our services, your device and
data (“you”, “your”) when you use our website, content browser will automatically provide unique
or other services. information such as mobile device ID, internet
protocol (IP) address, cookie ID or online identifiers,
Individuals in the European Economic Area (EEA), operating system, browser type, time zone setting,
Switzerland and the UK should also read our section location and date and time of access.
about “Your EEA, Swiss & UK Rights”. • Our website may record website usage data
about how you navigate and engage with our
services, use our features, download materials,
1. Who does this privacy notice apply to? security logs will be kept, online activity data such
as clickstream data with URLs visited previously,
This notice applies to: page interaction information (such as scrolling,
clicks, and mouse-overs), your preferences
• our service users who access our services such as (including country and language), and methods
our website or content anywhere on the web, such used to browse away from our website. We may
as, users who watch our content, submit content collect data through our partners LiveRamp, Ipsos
to us, participate in our surveys and focus group iris and Google subject to your cookie consent
and other users; settings.
• our clients, suppliers and business partners; and • When you access our website or content, we
• other persons who interact with us, when you call collect information about your preferences and
us or email us. interests known, observed or inferred which we
use for personalisation and direct marketing.
This notice applies to you whether you act in your • Third party data about you such as information
personal capacity or as employee or agent of about your interaction with our posts and content
an organisation. and ‘likes’ on social media platforms, such as
Facebook, Twitter, Snap, TikTok, or LinkedIn, profile
information, preferences and interests received
2. What types of information do we collect? from our advertising and analytics partners and
other third parties.
Generally, “personal information”, “personal data” or
similar terms refer to any information that identifies Much of the personal data is provided by you or
you or relates to you. However, the exact meaning of automatically by your device. You can adjust your
personal information may be determined by the law device privacy settings to limit disclosure of your
of the country of your residence. personal data that is not necessary for our services.
We would ask that you only provide the necessary
We will process the following personal data about personal data to us.
you:
Some of the information will be necessary to
• Your contact details such as your email address assist you, to provide our services or to pursue our
when you sign up to our newsletter as a user legitimate interests in data processing. In certain
or your name, role, employer details, telephone limited cases, some personal data may be mandatory
number, email address and similar information for our compliance with the law.
when you interact with us in your business
capacity.
• When you contact or visit us, we may process your 3. Data accuracy
enquiry, communication, complaint and other
details of your enquiry. We will rely on the information provided by you as
• If you are a prospective client, we will keep your accurate, complete and up to date, so please keep us
personal and professional details and other informed of any changes. For example, if you change
opportunity records for sales purposes. your email address, please let us know so that we can
• If you engage with our focus groups or surveys, continue sending you our newsletter.
1
 3. Data accuracy
We will rely on the information provided by you as accurate, complete and up to date, so please
4. Whatkeep us informed
information of any
do we changes.
collect For example, if you change your email address, please let us
and why?
know so that we can continue sending you our newsletter.
Generally, we will use your personal data to (i) provide
and enable you to use our website, content and other
4. What
services, information
(ii) respond do we
to your queries, (iii) collect and why?
develop and
promote our organisation and services; (iv) ensure the
securityGenerally,
and technicalwe availability
will use your personal
of our data
services; andto (i) provide and
enable you to use our website,
(v) comply with the law.
content and other services, (ii) respond to your queries, (iii) develop and promote our
organisation and services; (iv) ensure the security and technical availability of our services; and
(v) comply with the law.

Purpose Personal data Legal ground for processing

(for individuals in the EEA, Switzerland and
UK only)

To assist and contact you in relation to your • contact details Necessary for our legitimate interest in
enquiry. • details of your enquiry responding to queries, developing
relationships and administering our business
or to take necessary steps at your request
prior to entering into a contract with you.

To provide our services to you, such as our • device & browser data Necessary for our legitimate interest in
website, content and other services. • engagement providing our website and content to you or,
information as the case may be, necessary for the
• website usage data performance of our contract with you.

To manage our business relationship with you • contact details Necessary for our legitimate interest in
using communications, management and • opportunity records understanding and maintaining our business
engagement tools. • preferences and relationships and administering our business.
interests
Purpose Personal data Legal ground for processing
• engagement
(for individuals in the EEA, Switzerland and
information
UK only)
To send you information which you have • contact details Service communications are necessary for the
requested about our services and service performance of our contract with you.
communications about matters relevant to your • preferences and Other notifications are necessary for our
use of our services and your engagement with us, interests legitimate interest in satisfying your
such as changes in our terms, events, etc. • - engagement
2- requests, facilitating our services and
information organising related business activities.

To engage with you about surveys and focus • contact details Necessary for our legitimate interest in
groups. • participation developing our business and organising
information related business activities.
• engagement
information
To send you our newsletter and promotional • contact details We may rely on soft opt-in to send marketing
information through email about our services and • engagement to our existing clients or will obtain your
organisation, reviewing and optimising information consent as required by law, for example, if
campaign performance and profiling • preferences and you sign up for our newsletter.
information about your interests known, interests
observed or inferred for direct marketing • third party data Some of our direct marketing activities are
purposes. necessary for our legitimate interest in
understanding your interests from the
information available to us, information
observed or inferred and third party
information, in promoting our business and
understanding campaign metrics.

To display advertisements relevant to you on • contact details We will obtain your consent where required
websites and social media, reviewing and • engagement by law. For example, your consent will be
optimising campaign performance and information required to place cookies or similar
profiling information about your interests • preferences and technologies on your device or to read
known, observed or inferred for direct marketing interests information on your device.
purposes. • third party data
Some of our direct marketing activities are
For example, we use your contact details to necessary for our legitimate interest in
display relevant ads through Twitter or understanding your interests from the
LinkedIn or other social media platforms. Social information available to us, information
media and advertising providers may use their observed or inferred and third party
own information about you to help us make our information, in promoting our business and
ads more relevant. understanding campaign metrics.

Our partner LiveRamp will collect your device &

browser data and use digital fingerprinting
techniques to recognise your device for online
and cross-channel advertising purposes. It may
be shared with our advertising partners and other
third party advertising companies globally for the 2
purpose of enabling interest-based content or
targeted advertising throughout your online
experience (e.g. web, email, connected devices,
and in-app, etc). These third parties may in turn
such as changes in our terms, events, etc. • engagement requests, facilitating our services and
information organising related business activities.

To engage with you about surveys and focus • contact details Necessary for our legitimate interest in
groups. • participation developing our business and organising
information related business activities.
• engagement
information
To send you our newsletter and promotional • contact details We may rely on soft opt-in to send marketing
information through email about our services and • engagement to our existing clients or will obtain your
organisation, reviewing and optimising information consent as required by law, for example, if
campaign performance and profiling • preferences and you sign up for our newsletter.
information about your interests known, interests
observed or inferred for direct marketing • third party data Some of our direct marketing activities are
purposes. necessary for our legitimate interest in
understanding your interests from the
information available to us, information
Purpose Personal data Legal ground
observed or for processing
inferred and third party
(for individuals
information, in in the EEA,our
promoting Switzerland and
business and
UK only)
understanding campaign metrics.

To display
users’ advertisements
computer, hardware andrelevant toFor
software. youmore
on • contact details We will obtain your consent where required
websites socialcontact
informationandplease media, Ipsos
reviewing
MORIand at • engagement by law. For example, your consent will be
optimising campaign performance
[email protected] or DotMetrics and at information required to place cookies or similar
profiling information
[email protected] about
or refer to theyour
Ipsos interests
iris site- • preferences and technologies on your device or to read
known, or inferred for direct
centric observedprivacy policy marketing at: interests information on your device.
purposes.
https://iris.ipsos.com/site-centric-privacy/ • third party data
Some of our direct marketing activities are
For example,
To ensure proper we useadministration
your contact details
of our to • all information as is necessary for
Necessary for our legitimate
ourlegitimate interest
interest in
in the
display relevant
business, including to: ads through Twitter or necessary and understanding your ofinterests
proper administration from
our business, the
dispute
•LinkedIn
keep or other socialrecords
appropriate media platforms.
about howSocial our proportionate for the information availabletechnical
resolution, ensuring to us, operation
informationof
media and advertising
services are used; providers may use their administration of our observed
our servicesor inferred
and debtandcollection
third party
and
own information about you to help us make our business information, in promoting our business
necessary for compliance with a legal and
• resolve complaints;
ads more relevant. understanding campaign
obligation to which we aremetrics.
subject.
• conduct troubleshooting;
Our manage
• our business
partner LiveRamp relationships
will collect your deviceand &
identify opportunities;
browser data and use digital fingerprinting
• registerto recognise
techniques interactions
your device withfor online
our
and communications, such as emails;
cross-channel advertising purposes. It may
enforcewith
• shared
be our our
terms; and
advertising partners and other
• debt
third partycollection.
advertising companies globally for the
purpose of enabling interest-based content or
targeted our third party
To engageadvertising service providers
throughout your onlinewho • all information as is Some activities are necessary for the
may process(e.g.
experience yourweb,
information on our behalf
email, connected devices,to necessary and performance of our contract with you,
facilitate
and in-app, theetc).
provision of our
These third services
parties mayand the
in turn proportionate to others are necessary for our legitimate
fulfilment
use this code of essential
to link service functions,
demographic such as
or interest- enable the relevant interest in ensuring the proper operation of
web hosting,
based cloud you
information storage,
haveanalytics,
providedpayments,
in your service our services.
plugins, communications,
interactions with them. If you accounting,
wish to optsecurity
out
and others.
from LiveRamp’s processing, please go to
https://liveramp.com/opt_out/
To monitor our networks, website and systems for • website usage data Necessary for our legitimate interest to
suspicious activities, test and audit our systems • device & browser data ensure the security of our organisation,
andimprove
To deploy appropriate
and develop security measures.
our services, including • Aggregated data based people andfor services
Necessary and necessary
our legitimate interest for
in
to: on your participation complianceour
delivering with a legal properly,
services obligationefficiently
to which
• obtain feedback; information, we are
and subject.
understanding our customer’s needs and
• use Google Analytics and Ipsos iris to engagement expectations.
To monitor
understand interactions and operations
the demographics of our for
usersfraud
and • contact detailsdevice &
information, Necessary for our legitimate interest in
prevention
for audience andmeasurement;
crime detection purposes, • browser & device
data, data
website detecting
We will useand preventing
cookies fraudtechnologies
and similar and illegal
•including
conduct information from third parties who
statistical analysis; • website usage
usage data data and ifconduct and necessary
you provided for compliance with a
your consent.
•maymake
help us verifyand
services yourfeatures
identitymore
or alert us about
relevant; • preferences
third party data and legal obligation to which we are subject.
suspicious activities. interests.
• improve user experience;
• work with third parties and evaluate data to
To process health information provided by you, • health information Where necessary and proportionate, in order
improve and develop our services.
inform you of government guidance and, where provided by you to satisfy our legitimate interest in
appropriate, inform third parties about the risk of complying with best practice or applicable
Our partner the UK Online Measurement
infection or share information with relevant laws, and where necessary for compliance
company has retained Ipsos MORI and
authorities. with a legal obligation to which we are
DotMetrics to deploy tags and digital fingerprint
subject, or to establish, exercise or defend
techniques on our website to collect information
legal claims or to fulfil our duty of care owed
about our users’ online behaviour and about our
to third parties.

To share information with our affiliated • all information as is Necessary for our legitimate interest in
companies. - necessary
3- and using our group’s resources to organise,
proportionate develop and deliver our services, run our
organisation and decide on future strategies.

To share data with another organisation in • all information as is Necessary for our legitimate interest in
accordance with the law for the purposes of a joint necessary and acting in the best interest of our shareholders
venture, collaboration, financing, sale, merger, proportionate in and investors and complying with our legal
reorganisation or similar event relating to our connection with the obligations.
business. event

To process information as is required for our • Any information Where processing or sharing your data is
compliance with the law or to establish, exercise subject to mandatory necessary for compliance with a legal
or defend legal claims. processing or obligation to which we are subject, to
disclosure, where this establish, exercise or defend legal claims,
To process and share information with other third is necessary and or, where necessary and proportionate, in 3
parties where required by law, such as regulators, proportionate order to satisfy our legitimate interest in
law enforcement agencies or where mandatory complying with best practice or applicable
under a court order. laws.
 Purpose Personal data Legal ground for processing
(for individuals in the EEA, Switzerland and
UK only)

users’ computer, hardware and software. For more

information please contact Ipsos MORI at
[email protected] or DotMetrics at
[email protected] or refer to the Ipsos iris site-
centric privacy policy at:
https://iris.ipsos.com/site-centric-privacy/

To ensure proper administration of our • all information as is Necessary for our legitimate interest in the
business, including to: necessary and proper administration of our business, dispute
• keep appropriate records about how our proportionate for the resolution, ensuring technical operation of
services are used; administration of our our services and debt collection and
• resolve complaints; business necessary for compliance with a legal
• conduct troubleshooting; obligation to which we are subject.
• manage our business relationships and
identify opportunities;
• register interactions with our
communications, such as emails;
• enforce our terms; and
• debt collection.

To engage our third party service providers who • all information as is Some activities are necessary for the
may process your information on our behalf to necessary and performance of our contract with you,
facilitate the provision of our services and the proportionate to others are necessary for our legitimate
fulfilment of essential service functions, such as enable the relevant interest in ensuring the proper operation of
web hosting, cloud storage, analytics, payments, service our services.
plugins, communications, accounting, security
and others.

To monitor our networks, website and systems for • website usage data Necessary for our legitimate interest to
suspicious activities, test and audit our systems • device & browser data ensure the security of our organisation,
and deploy appropriate security measures. people and services and necessary for
compliance with a legal obligation to which
we are subject.

To monitor interactions and operations for fraud • contact details Necessary for our legitimate interest in
prevention and crime detection purposes, • browser & device data detecting and preventing fraud and illegal
including information from third parties who • website usage data conduct and necessary for compliance with a
may help us verify your identity or alert us about • third party data legal obligation to which we are subject.
suspicious activities.

To process health information provided by you, • health information Where necessary and proportionate, in order
inform you of government guidance and, where provided by you to satisfy our legitimate interest in
appropriate, inform third parties about the risk of complying with best practice or applicable
infection or share information with relevant laws, and where necessary for compliance
authorities. with a legal obligation to which we are
subject, or to establish, exercise or defend
legal claims or to fulfil our duty of care owed
to third parties.

To share information with our affiliated • all information as is Necessary for our legitimate interest in
companies. necessary and using our group’s resources to organise,
proportionate develop and deliver our services, run our
organisation and decide on future strategies.

To share data with another organisation in • all information as is Necessary for our legitimate interest in
accordance with the law for the purposes of a joint necessary and acting in the best interest of our shareholders
venture, collaboration, financing, sale, merger, proportionate in and investors and complying with our legal
reorganisation or similar event relating to our connection with the obligations.
business. event

To process information as is required for our • Any information Where processing or sharing your data is
compliance with the law or to establish, exercise subject to mandatory necessary for compliance with a legal
or defend legal claims. processing or obligation to which we are subject, to
disclosure, where this establish, exercise or defend legal claims,
To process and share information with other third is necessary and or, where necessary and proportionate, in
parties where required by law, such as regulators, proportionate order to satisfy our legitimate interest in
law enforcement agencies or where mandatory complying with best practice or applicable
under a court order. laws.

-4-
4
We will update you about any new purposes of For example, third party cookies will enable providers
processing of your personal data from time to time, to find out how you used our services and combine
and we will obtain your prior consent for such new that information with other third party information.
purposes where we are required to do so at law. Advertising cookies deployed by third-party service
providers remember your browsing activity and
group together your interests which they know,
5. Cookies and similar technologies observe or infer to send you personalised ads. Such
personalisation is only possible because of profiling
What are cookies and similar technologies? These carried out with information collected through
are technologies that enable us to store information, cookies and similar technologies. This may include
or access information stored, on your device such as your preferences, characteristics, behaviour and
your computer or smartphone. attitudes. We manage our ads through a variety
of digital marketing networks and advertisement
• Cookies are small text files sent to or accessed exchanges and use a range of advertising
by your web browser which will enable you to technologies.
navigate our online services and features but also
enable us to measure and improve engagement
with our audiences. They are used to recognise Acceptance
returning users by siting on your device and
making themselves known when you access our When you use our services, essential cookies and
systems. similar technologies which are required to provide our
• Pixels or tags are tiny graphics files that are services will be automatically set on your device.
downloaded when you interact with our services.
This will then alert us that you have opened an Others will also be set if you accept cookies and
email, clicked on content or other action. These are similar technologies by selecting your choices in the
typically used to capture interaction information cookie banner. As already mentioned, some cookies
and measure the relevance of our content. are provided by third parties and your acceptance of
• Tracking URLs are custom generated links that cookies will extend to such third parties.
help us understand where web traffic comes from.
• Local storage is used to more efficiently manage This means, for example, that if you chose to accept
the temporary storage of information that allows “Analytics” cookies we will feel encouraged to use
you to access our services on your device. Google Analytics and it will constitute consent for
• Digital fingerprint is used to recognise your Google to deploy its cookies which collect statistical
device based on your device & browser data information about how users interact with our
without relying on cookies. For this purpose, our services.
partners LiveRamp and Ipsos Iris may collect your
IP address, monitor settings, type of browser and
operating system to create a unique serial number How long are cookies used?
which constitutes a digital “fingerprint”.
The lifespan of each cookie may differ. We use both
session and persistent cookies. Session cookies only
Why do we use cookies and similar technologies? last until you close your browser. Persistent cookies
aren’t automatically deleted when you close your
Like most organisations with online presence, we use browser and they recognise returning users.
the following cookies and similar technologies to:

• provide our services which is not possible without Refusing cookies

certain essential cookies;
• remember your settings and preferences to You do not have to accept cookies (apart from
improve your experience, speed up your searches the essential ones), but without accepting them
and recognise you when you return to our service; the functionality of our services will be reduced.
• understand our online traffic through analytics We participate in the IAB Europe Transparency &
tools; Consent Framework (“TCF”) and operate a Consent
• personalise our marketing and advertising; and Management Platform which helps us to comply with
• connect you with our social media features. the cookies consent requirements. You can change
your cookie preferences at any time by clicking
To accomplish this, we will, in certain cases, also link “Change privacy settings” and mark your new choices.
information from cookies and similar technologies
with personal data held about you. While we try to ensure that your choices are
fully respected, this may not always be possible,
particularly where third parties are involved. For
Whose cookies and similar technologies are example, if you do not agree to “Social Media” cookies
deployed in connection with my device? but you still interact with our Instagram plugins in our
services, Facebook may set certain essential and non-
We will deploy cookies and similar technologies essential cookies outside our control. As discussed
ourselves. However, our services may also include below, you should read Facebook’s privacy notice for
cookies and similar technologies deployed by third more detail.
parties.
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For this reason, aside from relying on our cookie as may be required by law. Generally, we will keep
settings, please also consider: your personal information for 6 years from collection.
However, in practice the retention period will likely
• turning off the automatic download feature in your be shorter if the information is no longer needed or
browser, as described at allaboutcookies.org; longer if required for lawful purposes.
• opting out from online interest-based advertising After the retention period, your personal data will
from companies that participate in opt-out either be securely deleted or anonymised and it may
programs through the Digital Advertising Alliance, be used for analytical purposes. You must back up
the Interactive Digital Advertising Alliance, your data if you wish to keep it for longer.
Appchoices or Network Advertising Initiative. We
do not participate but some of our advertising
partners may do; and 9. How do we secure your information?
• opting out from third party services that deploy
cookies and similar technologies, such as Google We maintain appropriate organisational and
Analytics, by visiting www.google.com/settings/ technological safeguards to help protect against
ads or by downloading the opt-out add-on at unauthorised use, access to or accidental loss,
https://tools.google.com/dlpage/gaoptout. alteration or destruction of the personal data we
hold. We also seek to ensure our third-party service
providers do the same.
What happens if I disable cookies?
We will endeavour to use the least amount of
By disabling cookies, you may experience a reduced personal data as is required for each purpose. We
service. For example, opting out of the placement of will employ pseudonymisation and anonymisation
advertising cookies does not necessarily mean that techniques, where appropriate.
you will not see advertisements – it means you won’t
see personalised advertising. Our staff will access your personal data on a “need to
know” basis.
Note that if you delete or clear cookies on your device,
the next time you visit our website our cookie consent
banner will reappear, and you will need to select your 10. Where is your information processed?
preferences again. Remember that if you change your
settings to exclude cookies in your browser or device We may transfer your personal data to our affiliated
but later request services by interacting with our companies, suppliers and other third parties in
service features (e.g. you click on a social media plug- countries different to your country of residence.
in on our website), this may override your browser or Generally, your information is held in the United
device settings. Kingdom and the EEA.

We will comply with applicable rules about

6. Sharing your information international transfer of personal data.

We will share your information where it is lawful,

necessary and proportionate to do so with (i) our third 11. Opt-out
party service providers who may process personal
data on our behalf, (ii) our marketing and analytics If you would like us to stop sending you marketing
partners deploying cookies and similar technologies communications and to process your personal data
in our services and other partners, as explained above, for direct marketing purposes, please let us know.
(iii) our affiliated companies for the purposes set
out above, (iv) persons or authorities where we are You can request to stop receiving our marketing
compelled by law or responsible practices, (v) to the communications at any time by clicking on the
relevant entity in case of a merger, acquisition or unsubscribe link at the bottom of each marketing
collaboration, and (vi) other third parties where you message.
have provided your consent.

12. Contact us
7. Third parties may process your information
Please contact us at [email protected] or
Our services may contain links to other websites, third at our registered office address above if you have any
party services, such as Twitter and Instagram and queries or concerns about how we use your personal
plugins. You should check the privacy statements of data. We will try to resolve your query without undue
these third party providers before you use them as delay.
we are not responsible for how they may process your
personal data.
13. Updates
If we make any changes to our notice you will be able
8. How long is your information kept? to see them on this page. You should regularly check
We will keep your personal information for as long as for updates, as indicated by the “Last updated” date at
is necessary for the purposes listed above or longer, the top.

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If you do not agree with the changes, please do not
continue to use our website or services. Of course, if
any such changes significantly affect you, we will ask
for your prior consent where we are required to do so
by law.

14. Your EEA, UK and Swiss Rights

This section provides further disclosures and

describes the rights in relation to your personal
data that you may have under the General Data
Protection Regulation (“GDPR”) or other relevant
law if you are an individual in the EEA, Switzerland
or the UK.

A. Personal data
“Personal data” means any information relating to an
identified or identifiable natural person; such person
is known as a ‘data subject’. In practice, almost all
information relating to you will be your personal data.

B. How do we process your information and why?

We will process your personal data as “controller” for
the purposes and on the legal grounds for processing
set out above.

C. Data subject rights

Subject to certain exemptions, limitations and
appropriate proof of identity, as a data subject, you
will generally have numerous rights in relation to
your personal data that you may exercise with the
controller, including the following:

• Right to information about matters set out in this

notice. You may also contact us for further details
about our retention policy and international data
transfers.
• Right to make an access request to receive copies
of personal data.
• Right to rectification of any inaccurate or
incomplete personal data.
• Right to withdraw consent previously provided.
• Right to object to our processing of personal
data based on our legitimate interests, and any
automated processing and profiling.
• Right to erasure of personal data, within limited
circumstances.
• Restriction on the processing of personal data.
• Right to data portability from one service provider
to another, where applicable.
• Right to lodge a complaint with your country’s
supervisory authority, such as the Information
Commissioner’s Office in the UK.

All requests will be processed in a timely manner,

generally within one month. If we cannot process your
request within this period, we shall explain why and
process it as soon as possible thereafter.