Legal
Privacy Policy
How RBN Media LTD collects and uses personal data when you visit rbn-media.com, contact us, book a call or use the RBN Media Portal.
Last updated: {{PRIVACY_LAST_UPDATED}} · Draft [LEGAL REVIEW]
1. Who we are
RBN Media LTD ("RBN Media", "we", "us") is a company registered in England and Wales under company number {{COMPANY_NUMBER}}, with its registered office at {{REGISTERED_ADDRESS}}. We are the controller of the personal data described in this policy.
We are registered with the UK Information Commissioner's Office (ICO) under registration number {{ICO_REGISTRATION_NUMBER}}. [LEGAL REVIEW] Confirm the ICO registration (data protection fee) is in place.
Questions about this policy or your data: email {{PRIVACY_EMAIL}}.
We work business to business. Our services are not aimed at consumers or at anyone under 18, and we do not knowingly collect data about them.
2. What we collect
When you send the "Talk to us" form
- Your name, work email address and, if you give it, your company name
- The topic you choose and your message
- The page you sent it from, and your IP address (used briefly to limit repeated messages)
When you request access to, or use, the RBN Media Portal
- Your name, work email address and company name
- Your password, which we store only in hashed (irreversible) form
- Account details we add when we approve you, such as your pricing and catalog settings
- What you do in the portal: shortlists, orders, content approvals, messages, invoices and requests for new sites
- Billing details you give us for invoicing, such as company address and VAT number
- If you connect an AI assistant or use the API, the requests it makes to your account
When you book a call
Bookings are made through Google Calendar's appointment page. Google collects your name, email address and the time you choose, and sends us the booking with a Google Meet link. Anything you add in the booking form is shared with us.
When you visit the website
Our hosting provider records standard technical data for each request, such as IP address, browser type, the page requested and the time. The website loads its font from Google Fonts, so your browser also sends your IP address to Google when the page loads. [LEGAL REVIEW] Consider whether to self-host the font instead.
We do not use analytics, advertising or tracking tools on rbn-media.com.
3. Why we use it, and our lawful basis
| Purpose | Lawful basis (UK GDPR) |
|---|---|
| Replying to your enquiry and following up on it | Legitimate interests: responding to business enquiries |
| Reviewing access requests and running your portal account | Contract, or steps before entering into one |
| Processing orders, placements, invoices and payments | Contract; legal obligation for accounting and tax records |
| Holding calls you book with us | Legitimate interests, or steps before a contract |
| Keeping the website and portal secure, and preventing spam and abuse | Legitimate interests |
| Sending clients service updates and occasional news about new sites or features. You can opt out at any time by replying to any of these emails or writing to {{PRIVACY_EMAIL}} | Legitimate interests; for business email addresses, the rules on corporate subscribers under PECR. [LEGAL REVIEW] Our "new sites" emails currently have no unsubscribe link; PECR generally expects a simple opt-out in every marketing message |
We do not sell your personal data, and we do not use it for automated decisions that have legal or similarly significant effects on you.
4. Who we share it with
We use trusted service providers who process data on our behalf, under contracts that require them to protect it:
| Provider | What for |
|---|---|
| Render | Hosting the website and the portal |
| Airtable | Storing enquiries, portal accounts, orders and related records |
| Slack | Notifying our team of new enquiries |
| Calendar bookings and Google Meet, Google Fonts, and reCAPTCHA spam protection on portal sign-up and login | |
| GoDaddy | Domain and email hosting |
| AI assistants you connect (e.g. ChatGPT or Claude) | Only if you connect one to your account yourself; read-only access to your catalog |
[LEGAL REVIEW] Confirm this list is complete, for example accounting or payment providers, and that a data processing agreement is in place with each provider.
Where needed to deliver an order, we share the details of that order with the publisher placing your link, such as the target URL, anchor text and article. We do not share your contact details with publishers unless you ask us to.
We may also disclose data if the law requires it, to protect our rights, or as part of a sale or reorganisation of our business.
5. International transfers
Some of our providers store or process data outside the UK, mainly in the United States. Where they do, we rely on UK adequacy regulations (including the UK Extension to the EU-US Data Privacy Framework where the provider is certified) or on the UK International Data Transfer Addendum to the EU Standard Contractual Clauses. [LEGAL REVIEW] Confirm the transfer mechanism for each provider.
6. How long we keep it
- Enquiries that do not lead to an account: {{ENQUIRY_RETENTION}} after our last contact with you [LEGAL REVIEW]
- Portal accounts: for as long as the account is open, then {{ACCOUNT_RETENTION}} [LEGAL REVIEW]
- Orders, invoices and accounting records: six years after the end of the financial year they relate to, as UK law requires [LEGAL REVIEW]
- Portal activity history such as messages, content approvals, submitted articles and order history: we periodically delete these from the portal once they are older than about 180 days. Invoices and accounting records are kept separately for the period above [LEGAL REVIEW]
- Server logs and rate-limiting data: rate-limiting data is held in memory for minutes; hosting logs are kept for as long as our hosting provider retains them
7. Cookies
rbn-media.com does not set cookies. The RBN Media Portal uses only cookies that are strictly necessary to keep you logged in securely, so it does not ask for cookie consent. Google reCAPTCHA, used on portal sign-up and login, may set its own cookies to tell people from bots. [LEGAL REVIEW] Confirm whether reCAPTCHA needs a consent mechanism.
8. Your rights
Under UK data protection law you have the right to:
- access the personal data we hold about you
- have inaccurate data corrected
- have your data erased
- restrict or object to how we use it, including objecting to direct marketing at any time
- receive your data in a portable format
To use any of these rights, email {{PRIVACY_EMAIL}}. We will reply within one month. If you are unhappy with how we handle your data, you can complain to the Information Commissioner's Office at ico.org.uk. We would appreciate the chance to put things right first.
9. Security
All traffic to the website and the portal is encrypted (HTTPS). Passwords are stored hashed, admin access requires two-factor authentication, logins and forms are rate-limited, and access to client data is restricted to the people who need it. No system is perfectly secure, but we work to protect your data and will tell you and the ICO about a breach where the law requires.
10. Changes and contact
We may update this policy from time to time. The latest version is always on this page, with the date at the top. If a change materially affects how we use your data, we will tell portal clients by email.
Contact: {{PRIVACY_EMAIL}} · RBN Media LTD, {{REGISTERED_ADDRESS}}