1.1 Our Commitment
Ascendia Prime is committed to complying with applicable data protection laws, including the UK GDPR, the Data Protection Act 2018 and, where applicable, the EU GDPR and ePrivacy rules.
We aim to embed privacy, security, transparency and accountability into our operations and digital marketing activities.
1.2 Data Protection Principles
We seek to process personal data in line with the following principles:
- Lawfulness, fairness and transparency.
- Purpose limitation.
- Data minimisation.
- Accuracy.
- Storage limitation.
- Integrity and confidentiality.
- Accountability.
1.3 Privacy by Design
We aim to consider privacy at the design stage of campaigns, tracking solutions, retargeting activity, publisher onboarding, CRM processes, reporting and data sharing.
Where appropriate, we assess:
- What data is needed.
- Why it is needed.
- The lawful basis for processing.
- Whether consent is required.
- How long data should be retained.
- Who has access.
- Whether data is shared internationally.
- Whether individuals have been properly informed.
- Whether risk can be reduced through minimisation, aggregation, pseudonymisation or contractual controls.
1.4 Controller and Processor Responsibilities
Where Ascendia Prime acts as a controller, we are responsible for determining the purpose and means of processing.
Where Ascendia Prime acts as a processor, we process personal data on documented instructions from the relevant controller and apply appropriate contractual, technical and organisational safeguards.
Where roles are unclear, we aim to define responsibilities in writing before processing begins.
1.5 Records and Accountability
We aim to maintain appropriate records of processing activities, contracts, data processing agreements, supplier arrangements, consent mechanisms, privacy notices and data protection decisions.
1.6 Data Subject Rights
Individuals may have rights to access, correct, delete, restrict, object to or receive a copy of their personal data.
Requests should be sent to: cs@ascendiaprime.com
We aim to respond within the legally required timeframe. In some cases, we may need to verify identity or request additional information.
1.7 Direct Marketing and Opt-Outs
We respect marketing preferences and opt-outs.
Where we send marketing communications, we aim to ensure that such communications are lawful, relevant and easy to opt out from.
We maintain suppression lists where required to ensure that people who opt out are not contacted again for the same type of marketing.
1.8 Cookies, Pixels and Tags
Digital advertising and affiliate marketing often depend on cookies, pixels, tags and similar technologies.
We expect our website, advertisers and partners to use these technologies lawfully and transparently. Where consent is required, it should be obtained before non-essential tracking is activated.
Ascendia Prime may require advertisers or partners to confirm that appropriate cookie notices, consent tools and privacy disclosures are in place before campaign activation.
1.9 Data Sharing and Contracts
Where personal data is shared with advertisers, publishers, platforms, suppliers or technology providers, we aim to ensure appropriate contractual terms are in place.
These may include:
- Data processing agreements.
- Controller-to-controller data sharing terms.
- Confidentiality obligations.
- Security requirements.
- Audit and cooperation provisions.
- International transfer safeguards.
- Breach notification obligations.
- Restrictions on unauthorised use.
1.10 Security and Breach Management
We maintain proportionate security controls to protect personal data.
If a personal data breach occurs, we will assess the risk, take steps to contain and remediate the issue, and notify regulators or affected individuals where legally required.
1.11 International Data Transfers
Where personal data is transferred outside the UK or EEA, we aim to use appropriate safeguards such as adequacy decisions, the UK International Data Transfer Agreement, the UK Addendum, EU Standard Contractual Clauses or other lawful transfer mechanisms.
1.12 Partner Expectations
Advertisers, publishers, networks, media buyers, influencers and suppliers working with Ascendia Prime must:
- Use personal data lawfully.
- Provide accurate privacy and cookie disclosures.
- Honour consent and opt-out choices.
- Avoid unlawful scraping, spam, hidden tracking or data misuse.
- Maintain appropriate security.
- Cooperate with data protection requests and investigations.
- Notify Ascendia Prime promptly of any actual or suspected data incident affecting our campaigns or partners.
1.13 Data Protection Contact
For data protection matters, contact:
Email: cs@ascendiaprime.com
Postal address: Ascendia Prime Media Ltd, Unit 13e, First Floor Office, 27 Town Square, Erith, Kent, United Kingdom, DA8 1SE.