1.1 Introduction
Ascendia Prime Media Ltd (“Ascendia Prime”, “we”, “us”, or “our”) respects privacy and is committed to protecting personal data.
This Privacy & Cookies Policy explains how we collect, use, store and share personal data when individuals interact with our website, services, campaigns, affiliate network, tracking technologies, business communications, advertisers, publishers, agencies, suppliers and partners.
Ascendia Prime operates in performance marketing, affiliate marketing, digital media, retargeting, remarketing, publisher partnerships and campaign management. As part of this activity, we may process personal data in order to deliver, measure, optimise and report on marketing performance.
We aim to process data lawfully, fairly, transparently and responsibly.
1.2 Who We Are
Ascendia Prime Media Ltd is a private limited company registered in England and Wales under company number 16296718.
Registered office:
Unit 13e, First Floor Office,
27 Town Square,
Erith, Kent,
United Kingdom,
DA8 1SE.
For privacy matters, please contact:
Email: privacy@ascendiaprime.com
Postal address: Ascendia Prime Media Ltd, Unit 13e, First Floor Office, 27 Town Square, Erith, Kent, United Kingdom, DA8 1SE.
1.3 Our Role as Controller or Processor
Depending on the activity, Ascendia Prime may act as:
Data controller where we decide why and how personal data is processed, for example when we process website enquiries, business contacts, partner applications, supplier records, internal business communications or compliance records.
Data processor where we process personal data on behalf of an advertiser, client, network or platform under written instructions, for example when implementing campaign tracking, reporting or performance optimisation on behalf of a client.
Joint or independent controller in some affiliate marketing, publisher, tracking or digital advertising scenarios, depending on the structure of the campaign, the technology used and the contractual relationship between the parties.
Where required, we put appropriate data processing, data sharing or controller-to-controller arrangements in place.
1.4 Personal Data We May Collect
We may collect and process the following categories of data:
Business contact data
Name, job title, company name, email address, telephone number, postal address, LinkedIn profile, meeting notes and communication history.
Advertiser and publisher data
Company details, account contacts, finance contacts, authorised signatories, tax or billing details, campaign preferences, publisher applications, approval status, programme terms and communication records.
Campaign and tracking data
Click IDs, affiliate IDs, publisher IDs, campaign IDs, order IDs, transaction values, commission values, conversion events, timestamps, referral URLs, landing page URLs, device type, browser type, IP address, approximate location, cookie IDs, pixel events and attribution data.
Website and technical data
IP address, device identifiers, browser type, operating system, pages visited, time on site, session behaviour, referring websites, cookie preferences, consent records and analytics data.
Marketing and communication data
Newsletter preferences, event interactions, webinar registrations, call recordings where notified, CRM notes and opt-in or opt-out records.
Compliance and fraud prevention data
Traffic quality signals, suspicious click patterns, invalid activity indicators, fraud investigation notes, policy breaches, complaints, suppression lists and audit records.
Recruitment or supplier data
Where applicable, CVs, supplier contact information, due diligence records, contract records, payment details and references.
We do not intentionally collect special category data unless it is necessary, lawful and clearly explained at the point of collection.
1.5 How We Collect Personal Data
We may collect personal data:
- Directly from you when you contact us, complete a form, book a call, sign an agreement, apply as a partner or communicate with us.
- From advertisers, publishers, affiliate networks, media platforms, tracking platforms, analytics providers and business partners.
- Through cookies, pixels, tags, tracking links, server logs and similar technologies.
- From public sources such as company websites, professional networks and business directories.
- From events, conferences and business introductions.
- From fraud prevention, compliance, campaign monitoring and reporting systems.
1.6 Why We Use Personal Data
We may use personal data for the following purposes:
- To provide performance marketing, affiliate marketing, retargeting, remarketing, campaign management and reporting services.
- To onboard advertisers, publishers, agencies, media buyers and partners.
- To manage affiliate programmes, campaigns, commission structures and publisher approvals.
- To track clicks, conversions, transactions, commissions and campaign performance.
- To detect, prevent and investigate fraud, invalid traffic, brand abuse, cookie stuffing, click injection, misleading activity or policy breaches.
- To manage contracts, insertion orders, payment records and commercial relationships.
- To respond to enquiries, complaints, data protection requests and support requests.
- To improve our website, services, technology and campaign performance.
- To send business communications, service updates and relevant marketing where lawful.
- To comply with legal, regulatory, tax, accounting and audit obligations.
- To protect our rights, systems, clients, partners and users.
1.7 Lawful Bases for Processing
We rely on one or more lawful bases depending on the context:
Contract: where processing is necessary to enter into or perform a contract with advertisers, publishers, suppliers, staff or partners.
Legitimate interests: where processing is necessary for our business interests or those of our clients and partners, provided those interests are not overridden by individual rights and freedoms. This may include B2B communications, campaign tracking, fraud prevention, performance optimisation, network administration and service improvement.
Consent: where required, including for certain cookies, direct marketing, retargeting technologies or optional communications.
Legal obligation: where processing is necessary to comply with legal, regulatory, tax, accounting, employment or reporting obligations.
Vital interests or public task: these are unlikely to apply to our normal business activities but may apply in exceptional circumstances.
1.8 Affiliate Tracking, Retargeting and Remarketing
Ascendia Prime may use affiliate tracking, retargeting and remarketing technologies to help advertisers re-engage users who have interacted with a website, advert, publisher link or campaign but have not completed a desired action.
This may involve cookies, pixels, tags, click IDs, device data, campaign identifiers and conversion tracking.
Where required, such technologies should only be activated where appropriate consent, notice and contractual approvals are in place. Advertisers and website owners are responsible for ensuring their own websites provide suitable privacy information and cookie consent mechanisms where required.
We aim to ensure that retargeting and remarketing activity is measured, responsible, proportionate and brand-safe.
1.9 Cookies and Similar Technologies
Cookies are small files placed on a device when visiting a website. Similar technologies include pixels, tags, SDKs, tracking links, local storage and server-side tracking.
We may use the following categories:
Strictly necessary cookies
Required for the website to function, security, fraud prevention, user session management and consent recording.
Analytics cookies
Used to understand website usage, improve content, measure traffic and assess performance.
Advertising and affiliate cookies
Used to measure campaign performance, attribute clicks and conversions, support affiliate commissions, manage retargeting and improve advertising relevance.
Functionality cookies
Used to remember user preferences and improve website experience.
Consent management cookies
Used to store cookie choices and consent preferences.
Non-essential cookies should not be used unless the user has provided consent where required. Users should be able to accept, reject or manage non-essential cookie choices.
1.10 Managing Cookie Preferences
Users can manage cookie preferences through our cookie banner or cookie settings tool where available.
Users may also block or delete cookies through browser settings. However, disabling certain cookies may affect website functionality, tracking accuracy, attribution or user experience.
1.11 Marketing Communications
We may send marketing communications to business contacts where lawful and relevant. Individuals can unsubscribe or object to marketing at any time.
We do not knowingly send unsolicited consumer marketing emails without valid consent or another lawful basis.
We maintain suppression records where required to ensure we respect opt-outs.
1.12 Sharing Personal Data
We may share personal data with:
- Advertisers, publishers, agencies and affiliate networks.
- Tracking, analytics, attribution and reporting providers.
- Retargeting, DSP, paid media and advertising technology providers.
- CRM, email, cloud hosting, storage and communication providers.
- Payment, finance, accounting and legal service providers.
- Fraud prevention, brand safety and compliance partners.
- Professional advisers, auditors, insurers and regulators.
- Law enforcement or public authorities where legally required.
- Potential buyers, investors or successors in the event of a business transaction.
We do not sell personal data in the sense of transferring personal information for money. However, digital advertising ecosystems may involve data sharing for attribution, measurement and campaign delivery, as explained in this policy.
1.13 International Transfers
Some of our partners, suppliers, platforms or technology providers may process data outside the United Kingdom or European Economic Area.
Where international transfers occur, we seek to ensure appropriate safeguards are in place, such as adequacy regulations, standard contractual clauses, the UK International Data Transfer Agreement, the UK Addendum, transfer risk assessments or equivalent safeguards.
1.14 Data Retention
We keep personal data only for as long as reasonably necessary for the purposes for which it was collected.
Typical retention periods may include:
- Business contact data: up to 6 years after last meaningful interaction, unless earlier deletion is appropriate.
- Contract and finance records: up to 6 or 7 years for legal, accounting and tax purposes.
- Campaign tracking and attribution records: as required for reporting, validation, payment, dispute resolution and fraud prevention.
- Complaints and compliance records: as long as necessary to investigate, resolve and evidence the matter.
- Cookie consent records: for a reasonable period to evidence consent choices.
- Suppression records: as long as necessary to respect marketing opt-outs.
Retention periods may vary depending on legal obligations, contractual requirements, disputes, fraud prevention needs or regulatory expectations.
1.15 Security
We apply appropriate technical and organisational measures to protect personal data against unauthorised access, loss, misuse, alteration or disclosure.
These may include access controls, password protection, secure cloud systems, limited user permissions, staff awareness, supplier due diligence, data minimisation, encryption where appropriate, logging, monitoring and incident response processes.
No system is completely secure, but we take reasonable steps to protect personal data.
1.16 Individual Rights
Depending on applicable law, individuals may have rights to:
- Be informed about how personal data is used.
- Access personal data.
- Correct inaccurate personal data.
- Request deletion of personal data.
- Restrict processing.
- Object to processing, including direct marketing.
- Request data portability.
- Withdraw consent where processing is based on consent.
- Complain to a data protection authority.
- Challenge certain automated decision-making where applicable.
To exercise rights, contact: cs@ascendiaprime.com
We may need to verify identity before responding.
1.17 Automated Decision-Making and Profiling
We may use campaign data, audience signals and performance data to support optimisation, segmentation, fraud detection, attribution and retargeting decisions.
We do not intend to make solely automated decisions that produce legal or similarly significant effects on individuals without appropriate safeguards.
1.18 Children
Our services are intended for businesses and adult users. We do not knowingly target or collect personal data from children.
1.19 Complaints to a Regulator
Individuals have the right to complain to the UK Information Commissioner’s Office or another relevant data protection authority.
We would appreciate the opportunity to resolve any concern first.
1.20 Updates to This Policy
We may update this Privacy & Cookies Policy from time to time. The latest version will be published on our website with the effective date.