Legal
Privacy policy
How we look after your personal data, and the rights you have over it.
Welcome to Pure Performance Media's privacy and cookies policy ("Policy"). We respect your privacy and are committed to protecting your personal data. This privacy notice will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from), social media accounts or any of our services or apps ("Sites") as well as where we interact in the course of our business, and tell you about your privacy rights and how the law protects you.
We will never sell your personal data to a third party.
1. Purpose of this Policy
This Policy aims to give you information on how Pure Performance Media collects and processes your personal data, through your use of our Sites, including any data you may provide when you contact us, use a product or service, or when you sign up to our newsletter or downloadable content or take part in a competition. Our Sites are not intended for children and we do not knowingly collect data relating to children.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
Controller
Pure Performance Media Limited is the controller and responsible for our Sites and for your personal data (collectively referred to as "Pure Performance Media", "we", "us" or "our" in this Policy).
We have appointed a Data Privacy Manager who is responsible for overseeing questions in relation to this Policy. If you have any questions about this Policy, including any requests to exercise your legal rights, please contact the Data Privacy Manager using the details set out below.
Contact details
Full name of legal entity: Pure Performance Media Limited, registered in England and Wales under company number 14038738.
Registered office: Plus X Brighton, Lewes Road, Brighton, England, BN2 4GL
Data Privacy Manager: Jason Baker
Email address: info@pureperformancemedia.com
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK regulator for data protection issues (ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO, so please contact us in the first instance.
Changes to this Policy and your duty to inform us of changes
We keep our privacy policy under regular review. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
Third party links
Our Sites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our Sites, we encourage you to read the privacy policy of every website you visit.
2. The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data). We may collect, use, store and transfer different kinds of personal data about you 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 and gender.
- 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 to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access our Sites.
- Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.
- Usage Data includes information about how you use our Sites, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you. In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.
3. How is your personal data collected?
We use different methods to collect data from and about you, including through direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our Sites;
- subscribe to our service or publications;
- request marketing to be sent to you;
- enter a competition, promotion or survey; or
- give us feedback or contact us.
Automated technologies or interactions. As you interact with our Sites, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our cookie policy for further details.
Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources, including analytics providers such as Google Analytics based outside the UK, and advertising networks including Marketing Town and Databowl based inside the UK.
4. How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- Where we need to perform the contract we are about to enter into or have entered into with you or one of our customers or providers.
- Where it is necessary for our legitimate interests (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.
We rely on consent as one of the legal bases for processing your personal data where you have expressly given it. In relation to sending third party direct marketing communications to you via email or text message we will only rely upon consent. You have the right to withdraw consent to marketing at any time by contacting us.
Purposes for which we will use your personal data
Below is a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. Note that we may process your personal data for more than one lawful ground depending on the specific purpose. Please contact us if you need details about the specific legal ground we are relying on where more than one has been set out.
| Purpose or activity | Type of data | Lawful basis |
|---|---|---|
| To register you as a new client | Identity, Contact | Performance of a contract with you |
| To process and deliver your order, including managing payments, fees and charges, and collecting and recovering money owed to us | Identity, Contact, Financial, Transaction, Marketing and Communications | Performance of a contract with you. Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you, including notifying you about changes to our terms or privacy policy, and asking you to leave a review or take a survey | Identity, Contact, Profile, Marketing and Communications | Performance of a contract with you. Necessary to comply with a legal obligation. Necessary for our legitimate interests (to keep our records updated and to study how customers use our products and services) |
| To enable you to partake in a competition or complete a survey | Identity, Contact, Profile, Usage, Marketing and Communications | Performance of a contract with you. Necessary for our legitimate interests (to study how customers use our products and services, to develop them and grow our business) |
| To administer and protect our business and Sites, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data | Identity, Contact, Technical | Necessary for our legitimate interests (running our business, provision of administration and IT services, network security, fraud prevention, and in the context of a business reorganisation). Necessary to comply with a legal obligation |
| To deliver relevant Site content | Identity, Contact, Profile, Usage, Marketing and Communications, Technical | Necessary for our legitimate interests (to study how customers use our products and services, to develop them, to grow our business and to inform our marketing strategy) |
| To use data analytics to improve our Sites, products and services, marketing, customer relationships and experiences | Technical, Usage | Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Sites 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 | Identity, Contact, Technical, Usage, Profile, Marketing and Communications | Necessary for our legitimate interests (to develop our products and services and grow our business) |
Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
Third party marketing. We will always get your express opt-in consent before we share your personal data with any third party for marketing purposes.
Opting out. You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us. Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a service purchase, warranty registration, service experience or other transactions.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
5. Disclosures of your personal data
We do not sell your personal data, and we do not share it with third parties for their own marketing purposes.
We do use a small number of service providers who process personal data on our behalf, under contract and on our instructions only. They cannot use your data for their own purposes. The providers involved in running this website and handling enquiries are:
| Provider | What they do for us | Where |
|---|---|---|
| Cloudflare | Hosts and serves this website, and protects it from automated abuse | Global, UK adequacy or SCCs |
| HubSpot | Our CRM. Enquiries submitted through our forms are recorded here, along with the meeting booking tool | EU data centre |
| Resend | Delivers enquiry notification emails to us | EU and US, SCCs |
| Google Analytics | Aggregate website usage reporting. Only active if you accept analytics cookies | Global, SCCs |
We may also share personal data with professional advisers, including lawyers, accountants, auditors and insurers, and with HM Revenue and Customs, regulators and other authorities where we are required to do so by law.
Where we generate leads on behalf of a client, and you have consented to your details being passed to that client, we will share your data with them. They become a controller of that data in their own right at that point, and their own privacy policy applies. We tell you who the client is at the point we ask for your consent.
If our business is sold or reorganised, personal data may be transferred to the acquiring party. We will notify you before that happens.
6. International transfers
Many of our external third parties are based outside the UK, so their processing of your personal data may involve a transfer of data outside the UK. Whenever we transfer your personal data out of the 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 your personal data to countries that have been deemed to provide an adequate level of protection for personal data, or we will use approved Standard Contractual Clauses as provided by the ICO or the European Commission.
Where we use certain service providers, we may use specific contracts, including our own data processing agreement approved for use in the UK, which give personal data the same protection it has in the UK. Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the UK.
7. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. We seek to use third party technology providers that are ISO27001 certified or equivalent (SOC II) where practical.
8. Data retention
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction Data) for six years after they cease being customers, for tax purposes.
In some circumstances you can ask us to delete your data. In some circumstances we will anonymise your personal data, so that it can no longer be associated with you, for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
9. Your legal rights
Under certain circumstances, you have rights under data protection laws in relation to your personal data. 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 lawfully processing it.
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, where we may have processed your information unlawfully, or where we are required to erase your personal data to comply with local law. Note that we may not always be able to comply with your request of erasure for specific legal reasons, which will be notified to you 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 fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. 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 if you want us to establish the data's accuracy, where our use of the data is unlawful but you do not want us to erase it, 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 where 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. 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. 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 clearly unfounded, repetitive or excessive. Alternatively, we could 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 your 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 has no right to receive it. We may also contact you to ask 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 within one month. Occasionally it could take us longer than a month 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.
10. Glossary
Lawful basis
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service and product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or are otherwise required or permitted to by law.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party, or to take steps at your request before entering into such a contract.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External third parties
- Service providers acting as processors based in the UK and India who provide IT and system administration services.
- Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
- HM Revenue and Customs, regulators and other authorities based in the United Kingdom who require reporting of processing activities in certain circumstances.
11. Cookies
Our Sites use cookies to distinguish you from other users of our website. This helps us to provide you with a good experience when you use our Sites and also allows us to improve them. For full detail of the cookies we use and how to control them, please see our cookie policy.
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly.
12. Automated decision making
We do not make decisions about you based solely on automated processing that produce legal effects or similarly significant effects for you. We do use automated tools to segment audiences and prioritise outreach, but a person reviews and decides before any lead is qualified or passed on.
13. Call recording
Outbound and inbound calls made as part of a campaign are recorded and transcribed for quality assurance, compliance and lead verification. You are told at the start of the call that it is being recorded. Recordings are retained for the period agreed with the relevant client, then deleted. You can ask for a copy of a recording of your own call, or ask us to delete it, using the contact details above.
14. Complaints
If you are unhappy with how we have handled your personal data, please contact us first at info@pureperformancemedia.com so we have the chance to put it right. You also have the right to complain to the Information Commissioner's Office at ico.org.uk, or by calling 0303 123 1113.
Questions
Contact us at info@pureperformancemedia.com.
Last updated 9 August 2026
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