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Privacy Policy

Privacy Policy

Updated 23/05/18

1. Our Data Protection Promise

The General Data Protection Regulation (GDPR) is a new European data protection law coming into force on 25 May 2018 which will harmonise the law regarding the personal data of individuals in the EU. Stray FM Ltd is firmly committed to complying with the GDPR and we are committed to handling personal data responsibly and compliantly. To achieve this, we have reviewed our existing policies and procedures on data protection and as a result of this review, we have: • Refreshed our current data protection policies. • Confirmed our cyber security measures continue to be robust and fit-for-purpose • Ensured we have up-to-date records of any personal data that we hold • Communicated this with all Stray FM representatives, representatives and third party business partners to ensure that they are committed to achieving the same standards of data protection practices that we set ourselves. We will work with our partner companies to ensure that any personal data they are using on our behalf is processed fairly, lawfully and transparently. Stray FM takes its role as a data controller and processor very seriously, and the privacy of clients, customers, representatives and audiences is of utmost importance. This policy sets out Stray FM’s practice under the General Data Protection Regulation, with the appointed data controller being: Stray FM Limited, Carn Brea Studios, Barncoose Industrial Estate, Redruth, Cornwall TR15 3RQ. Stray FM Limited's registration number is Z7699011.

2. Use of Personal Information, what data do we collect?

Personal information recorded during your registration is used only by Stray FM. For example, we may provide you with information that we think will be of interest to you or contact you with online security advice, in provision of the services you request. We will not divulge your personal details to other organizations, we may however, share your details between associated companies within our group, as defined by section 736 of the Companies Act 1985. We may also share your details with companies we are in partnership with in order to offer prizes and competitions to you. We will only use the email addresses of registered users to send emails explicitly requested by the user (opt-in), you will receive marketing information where all emails will be from Stray FM and not from any un-associated third party. You have the right to update information we store about you at any time, or to request that we remove it from our systems. Under the General Data Protection Regulation users have the right to access information collected by Stray FM about them. You can unsubscribe or close your membership account with us at anytime by logging in and clicking "Manage Your Subscriptions" or "Delete Your Account".

3. Security of data:

Stray FM is committed to the security of your information. We take every precaution to prevent unauthorised access to your information. We cannot protect the information which is collected by a third party owned site which is linked to our site. Stray FM takes every precaution to secure data. Representatives must ensure that they create strong passwords and do not share these with anyone else, including other representatives. Stray FM systems will ask representatives to update their passwords on a regular basis. All Stray FM systems are protected using HTTPS and SSL technology.

4. Recording & Storage of Personal data, how do we collect and store Personal Information?

Should you choose to register with Stray FM, we will collect basic personal information to complete your registration. This will include your name, and your email address. We may also collect personal demographic information, such as your postcode, preferences and interests, details of use and transactions made through this site. Stray FM also records limited information about your computer hardware and software, including (but not limited to) your operating system, browser type, IP address, access times and referring URLs. We also keep track of pages visited by our users to help us maintain and improve our services. All Stray FM representatives are to record and store data according to this policy. All data stored by Stray FM must include a source of the data (ie. Where the data came from) and the legal basis for storing. Stray FM’s key data sources and practice are defined as below: Digitally collected data via StrayFM.com: When individuals register with StrayFM.com we will collect basic personal information to complete their registration. This will include their name, and email address. We may also collect personal demographic information, such as postcode, preferences and interests, details of use and transactions made through this site. This data is kept securely on Stray FM’s content management system and is only accessible to representatives with the appropriate level of clearance. Individuals will see a message giving them the opportunity to view Stray FM’s Privacy Policy and opt in to data storage when registering their details. This data will be stored until an individual removes their account, via the “Manage Your Subscriptions” option, or it will be automatically deleted if the account is inactive for a period of 5 years.

Data collected via telephone: Stray FM will collect the data of individuals over the telephone for use in competitions and for arranging content (eg interviews). This data will be used solely for the purpose of providing a prize or for creating radio or online content. This data may be stored securely in Stray FM’s CRM system or database for a period of up to 24 months for record keeping purposes. Where contractually obliged we will hold this data for longer periods. Individuals can request access to this data at any time using the right of access procedure.

Client Data: Stray FM stores data relating to businesses and individuals via its secure online CRM system. The majority of this data is stored and processed under a Contractual legal basis, as it is required to fulfil the business functions in providing advertising services. Data of prospective and previous clients is stored and processed under the legal basis of Legitimate Interest, in order to provide clients our products and services when required. Stray FM representatives will log against the client record when their data is processed, and this is accessible to the individual under the right of access policy defined below. For avoidance of doubt, processing includes, but is not limited to: - Phone calls - Emails - Letters - Inclusion of personal data in a list Stray FM representatives will store the GDPR purpose, legal basis and source of the data when recording any new records.

5. Personal data for those under the age of 16

Stray FM does not knowingly collect data for individuals under the age of 13 for marketing purposes. Individuals over the age of 13, but under the age of 16 can sign up for an account at StrayFM.com with the consent of their parent or guardian. Where Stray FM processes data of under 13s for specific reasons, for example competitions that require nomination, this will always be with the consent of their parent/guardian. This will be collected via an online consent form, with transparent clear privacy statement about how the information will be used and stored.

6. Our App

If you use any of our apps on your mobile device we will process the following information: 1. Your location-You may decline this request, but this may mean that we cannot offer relevant services; 2. Your device ID, this will be processed automatically; 3. Your email address, if you create an account; 4. Your age and gender, if you provide it. 7. Right of Access All individuals have the right to view, update or have deleted any information that Stray FM holds about them. An individual can request access to their data by contacting Stray FM in writing at the following address: Stray FM, The Hamlet, Hornbeam Park, Harrogate, HG2 8RE Or via email to sarah.barry@strayfm.com Stray FM will provide full information in electronic format within 30 days of receiving the request and verifying the individual’s identity. Stray FM does not charge for data access requests.

8. Verifying Identity

As part of Stray FM’s commitment to protecting individuals’ data, all requests to access, change or delete data can only be undertaken by the individual in question. Stray FM will ask to see photographic identification before undertaking any manual changing or deleting of data or releasing any data to an individual. Where individuals can access their data themselves, either via StrayFM.com or Stray FM’s online CRM system, the individual’s log in details will allow them access to view or update their details.

9. Opting Out

Individuals can opt out of their data being used in particular ways at any time, either through the right of access process, or via a self-service online portal. For data stored on StrayFM.com (user accounts), individuals can log in user their credentials and then visit the “Manage Your Subscription” page. For data stored on Stray FM’s CRM system, a unique link can be provided to the individual to manage their data upon request. This will be authorised by the Data Controller. In all other cases, individuals should follow the right of access process, and the Data Controller will undertake any reasonable request within 30 days. You have the right to update information we store about you at any time, or to request that we remove it from our systems. Under the General Data Protection Regulation users have the right to access information collected by Stray FM about them. You can unsubscribe or close your membership account with us at anytime by logging in and clicking "Manage Your Subscriptions" or "Delete Your Account".

10. Withdrawing Consent

Where an individual has given consent to their data being stored and processed, this consent can be withdrawn at any time. This consent cannot be withdrawn retrospectively. (ie. Any processing that has already taken place will still have been consented to). At this point, data will be removed as per the Right of Access process.

11. Sharing of data

Stray FM will never sell the data of any individual. There are occasions where Stray FM will share personally identifiable data with other organisations. Stray FM will only work with other organisations that have appropriate security measures in place. These include:

3rd Party service providers


Provides Stray FM’s e-mailing services and as such shares data between platforms.All data is covered by Mail Chimp’s privacy policy.

Google Analytics & Advertising

As part of our Google Analytics tracking we have implemented the following features: Remarketing, Google Analytics Demographics and Interest Reporting. Individuals can opt-out of Google Analytics for Display Advertising by visiting Google's Tools We use Google Analytics and other Google services for reporting purposes and online advertising.

Organisation providing prizes

In order to fulfil obligations for providing prizes, Stray FM may provide the organisation responsible with personally identifiable information. This will only be used for the purposes of providing a prize and will be subject to the same controls as data held by Stray FM.

12. Cookies

Stray FM uses cookies to identify logged in users. A cookie is a small text file stored on your computer which is accessible by Stray FM and not by other websites. The file contains an identification number which helps us to authenticate registered users visiting our website. Cookies cannot be used to run programs or deliver viruses to your computer. For more information please review our Cookie Policy. You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually change this setting if you wish to do so. If you configure your browser to decline cookies from Stray FM, you will not be able to fully experience the features of this website. Advertisers and other third party websites may also use cookies, Stray FM has no control over this activity.

13. Changes to this policy:

Stray FM will occasionally update these Terms and Conditions and other Legal Statements. The date of the last change to this page is always displayed at the top. Stray FM encourages users to periodically review this statement. For more information on any issue relating to Stray FM's privacy policy, please contact us.