Terms & Conditions

INTERPRETATION

In these Terms and Conditions and any Order Confirmation, the following words and phrases have the meanings set out below.

Buyer — the organisation or individual purchasing a licence to use the Data and the party to these Terms and Conditions and any Order Confirmation.

Data — the personal data records supplied by Aura Media Group to the Buyer under an Order Confirmation, which may include co-registration leads, telesurvey responses, list rental data, or web leads generated directly by Aura Media Group or its brands.

Data Protection Laws — all applicable legislation relating to privacy, data protection, direct marketing and electronic communications in force from time to time, including the UK General Data Protection Regulation (UK GDPR), the Data Protection Act 2018, the Privacy and Electronic Communications Regulations 2003 (PECR), the Data (Use and Access) Act 2025, and applicable ICO guidance and codes of practice.

End Users — those persons or organisations specified in an Order Confirmation as permitted users to whom the Buyer may grant a sub-licence to use the Data in accordance with these Terms and Conditions.

Fee — the fee payable by the Buyer to Aura Media Group as set out in the Order Confirmation.

Licence Period — the period during which the Buyer is permitted to use the Data, as specified in the

Order Confirmation. Unless otherwise stated, the Licence Period is 28 days from the date of delivery.

Order Confirmation — the order form signed by the Buyer to which these Terms and Conditions apply.

Suppression Record — a record of any individual who has opted out of, objected to, or requested removal from marketing contact.

1. APPLICATION OF TERMS

1.1 Each Order Confirmation agreed between Aura Media Group and the Buyer shall be governed by these Terms and Conditions. In the event of any inconsistency between the Order Confirmation and these Terms and Conditions, the Order Confirmation shall prevail.

1.2 Payment of the Fee specified in the Order Confirmation and corresponding invoice irrevocably confirms the Buyer's acceptance of these Terms and Conditions on behalf of its organisation.

2. DATA SUPPLY

2.1 Aura Media Group supplies personal data to the Buyer from one or more of the following sources, as specified in the Order Confirmation:

(a) co-registration leads — data collected via third party partner websites where individuals have registered and been informed that their data may be shared with Aura Media Group and its clients;

(b) telesurvey data — data collected via third party telephone survey operators where individuals have responded to questions asked on behalf of Aura Media Group's clients;

(c) list rental data — data sourced from third party list owners and supplied to the Buyer for use within the Licence Period;

(d) direct web leads — data collected directly via Aura Media Group's own consumer-facing brand websites.

2.2 The source type applicable to each Order Confirmation will be indicated on the Order Confirmation. The Buyer acknowledges that different source types may carry different lawful bases and collection methods.

2.3 Aura Media Group will deliver the Data to the Buyer in the format and via the secure delivery method specified in the Order Confirmation. Any delivery date agreed between the parties is indicative only. Aura Media Group shall not be liable for any loss or damage resulting from late delivery. Aura Media Group reserves the right to supply the Data in instalments.

3. LICENCE TO USE DATA

3.1 In consideration of payment of the Fee, Aura Media Group grants the Buyer a non-exclusive, non-transferable licence to use the Data for the purposes and during the Licence Period specified in the Order Confirmation.

3.2 The Buyer shall not copy, alter, manipulate, adapt or sub-licence the Data except as expressly permitted in the Order Confirmation.

3.3 The Buyer shall use the Data solely for the permitted marketing channel(s) specified in the Order Confirmation. Unless otherwise stated, use is limited to a single direct marketing campaign during the Licence Period.

3.4 Where the Order Confirmation expressly permits use by End Users, the Buyer warrants that each End User shall:

(a) comply with these Terms and Conditions as if it were the Buyer;

(b) not copy, alter, manipulate, adapt or sub-licence the Data;

(d) use the Data only for the permitted campaign and within the Licence Period.

3.5 The property, copyright, database rights and all other intellectual property rights in the Data shall at all times remain vested in Aura Media Group. Aura Media Group reserves the right to licence the same or similar data to other parties.

4. BUYER'S OBLIGATIONS

4.1 The Buyer shall at all times comply with Data Protection Laws in respect of its use, storage, and processing of the Data.

4.2 The Buyer warrants that it is, where required, registered with the Information Commissioner's Office (ICO) and will maintain such registration throughout the Licence Period.

4.3 The Buyer warrants that it is, where applicable, authorised and regulated by the Financial Conduct Authority (FCA) or any other applicable regulatory authority for the sector in which it operates, and will maintain such authorisation and regulation throughout the Licence Period.

4.4 The Buyer acknowledges that it is an independent data controller in respect of its own use of the Data. Aura Media Group is not responsible for the Buyer's processing of the Data once delivered. The Buyer accepts full responsibility for its own data processing activities, including compliance with Data Protection Laws.

4.5 The Buyer shall screen the Data against the Telephone Preference Service (TPS) and/or Mailing Preference Service (MPS) as applicable before use, and at no less than 28-day intervals during the Licence Period where the Data continues to be used.

4.6 The Buyer shall ensure that all marketing communications sent using the Data comply with all applicable laws, codes of practice and regulatory requirements, including the British Code of Advertising Practice, the CAP Code, PECR, and any sector-specific regulatory requirements.

4.7 The Buyer shall not pass, sell, transfer or otherwise disclose the Data to any third party without the prior written consent of Aura Media Group. This prohibition applies to the full Data set, any part of it, and any derivative records created from it.

4.8 The Buyer shall provide Aura Media Group with a suppression file of its existing customers and known opt-outs before delivery of the Data, where requested in the Order Confirmation.

4.9 The Buyer shall allow Aura Media Group to include a small percentage of seed and test records within the Data for quality control purposes.

4.10 Upon request by Aura Media Group, the Buyer shall promptly supply copies of any marketing communications sent using the Data.

5. OPT-OUTS, SUPPRESSION AND INDIVIDUAL RIGHTS

5.1 If any individual contacts the Buyer to object to marketing, request removal from any list, or exercise any right under Data Protection Laws, the Buyer shall:

(a) cease all marketing activity to that individual immediately;

(b) notify Aura Media Group in writing within 48 hours, providing the individual's name, contact details and the nature of the request;

(c) return a Suppression Record to Aura Media Group so that the individual can be added to Aura Media Group's suppression file and excluded from future supply.

5.2 The Buyer shall cooperate with Aura Media Group in responding to any Subject Access Request, right of erasure, right to restrict, or other data subject rights request relating to the Data.

5.3 Where an individual contacts Aura Media Group directly to object to marketing, request suppression, or exercise any right under Data Protection Laws in respect of data that has been supplied to the Buyer, Aura Media Group will notify the Buyer promptly. On receipt of such notification, the Buyer shall immediately cease all marketing activity to the relevant individual and confirm compliance to Aura Media Group within 48 hours.

5.4 The Buyer shall deliver to Aura Media Group any notice or communication received from the Information Commissioner's Office or any other regulatory authority relating to the Data within 24 hours of receipt.

6. CAMPAIGN PERFORMANCE DATA

6.1 Where requested by Aura Media Group, the Buyer shall provide campaign performance data in respect of the Data supplied, including call outcomes, contact rates, or sales results.

6.2 Where possible, the Buyer shall return performance data referenced by the unique record identifier (Lead ID) provided by Aura Media Group, rather than including personal identifiers such as name and telephone number. Where personal identifiers are included, data must be returned via a secure method agreed in writing with Aura Media Group.

6.3 Campaign performance data returned to Aura Media Group will be used solely for internal quality assurance and campaign optimisation purposes and will not be shared with third parties.

7. INTRODUCTIONS TO THIRD PARTY SERVICE PROVIDERS

7.1 Where Aura Media Group introduces a third party service provider to the Buyer — including call centres, telemarketing operators, or mail houses — that introduction is made as a facilitation only.

7.2 Aura Media Group may or may not receive a commercial benefit from such an introduction. The Buyer acknowledges this and accepts that any such benefit does not affect Aura Media Group's obligations under these Terms and Conditions.

7.3 Any arrangement entered into between the Buyer and an introduced third party is solely between those parties. Aura Media Group is not a party to that arrangement and accepts no responsibility for the performance, compliance, conduct, or regulatory status of any introduced third party.

7.4 The Buyer shall have no claim against Aura Media Group arising from its use of the services of any introduced third party, including any claim relating to data processing, marketing compliance, or regulatory investigation.

8. DATA QUALITY AND INVESTIGATION

8.1 Aura Media Group takes reasonable steps to ensure the accuracy of the Data at the point of supply. However, Aura Media Group does not warrant that the Data is accurate, complete, or that any information contained in it is accurate or complete at the point of use by the Buyer.

8.2 Aura Media Group gives no warranty or representation as to the performance of the Data or the rate at which it converts into sales or other commercial outcomes.

8.3 In the event of any complaint or dispute concerning the quality of the Data supplied, the Buyer may request an investigation subject to the following conditions:

(a) the Buyer or relevant End User must have made verbal or written contact with at least 25% of the individuals named in the Data set in question;

(b) the request for an investigation must be submitted to Aura Media Group within 7 days of the date of delivery of the relevant Data set;

8.4 On receipt of a valid investigation request, Aura Media Group will:

(a) randomly select a sample of records from the Data set and test them for accuracy and compliance;

(b) report to the Buyer on its findings within 5 Business Days.

8.5 Where an investigation reveals material concerns about Data quality, Aura Media Group may at its discretion — and without any obligation to do so — offer to replace some or all of the relevant Data or apply a credit against future orders. Any such offer is made as a goodwill gesture and shall not be construed as an admission of liability or as creating any warranty as to the accuracy of the Data.

8.6 No other remedy shall be available to the Buyer in respect of Data quality. The Buyer's sole recourse in respect of any Data quality dispute is the investigation procedure set out in this clause.

9. REGULATED SECTORS

9.1 Where the Buyer operates in a regulated or licensed market sector (including financial services, claims management, insurance, or telecommunications), the Buyer confirms that it holds all necessary authorisations, licences and registrations required to operate in that sector and to use the Data for the intended campaign.

9.2 The Buyer shall ensure that its use of the Data in a regulated sector complies with all applicable sector-specific regulatory requirements, including those imposed by the FCA, ICO, ASA, SRA, and any other relevant regulatory body.

9.3 The Buyer shall indemnify Aura Media Group against any losses, claims, regulatory penalties, costs, and expenses arising from the Buyer's use of the Data in a regulated sector, including any claim or investigation arising from the Buyer's failure to hold or maintain required authorisations or licences.

9.4 Nothing in these Terms and Conditions shall be construed as making Aura Media Group a legal representative, agent, or responsible party for the Buyer's regulated activities.

10. PAYMENT

10.1 The Fee payable for each Order Confirmation is set out in the relevant Order Confirmation. Unless otherwise stated, all Fees are exclusive of VAT, which will be charged at the prevailing rate.

10.2 Payment is due on a pro-forma basis unless otherwise agreed in writing. Aura Media Group reserves the right to withhold delivery of Data until payment is received.

10.3 Aura Media Group reserves the right to charge interest on any sum not paid by the due date at the rate of 2.5% per month above the prevailing Barclays Bank Base Rate, accruing daily from the due date until the date of actual payment.

10.4 Where Aura Media Group agrees to supply Data on a net names basis (where the Buyer pays only for records actually used following de-duplication), any claim for credit must be made within 14 days of delivery and must be supported by a written de-duplication report from a recognised independent data processing bureau approved by Aura Media Group.

10.5 Where Additional Data is supplied in excess of the Order Quantity, Aura Media Group may deliver and charge for up to 10% above the Order Quantity. No charge will be made for any overage above 10%.

11. CONFIDENTIALITY

11.1 The Buyer and its employees and agents shall keep confidential all information concerning the business, Data, pricing, and operations of Aura Media Group obtained or received in connection with any Order Confirmation.

11.2 In the event of the Buyer becoming aware of any unauthorised use of any part of the Data, the Buyer shall notify Aura Media Group in writing immediately.

12. TERMINATION

12.1 Aura Media Group may terminate any Order Confirmation immediately on written notice if:

(a) the Buyer commits a material breach of these Terms and Conditions and, where the breach is capable of remedy, fails to remedy it within 14 days of written notice requiring it to do so; or

(b) the Buyer becomes insolvent, enters administration, liquidation, or any analogous insolvency event.

12.2 The Buyer may cancel an Order Confirmation by providing written notice stating all reasons for cancellation at least one calendar month before the date on which Aura Media Group is due to begin delivery. Aura Media Group may decline to accept a cancellation request that does not meet this requirement or that forms part of an agreed series of orders.

12.3 On termination of any Order Confirmation the Buyer shall immediately cease all use of the Data, return or destroy all copies of the Data and any derivative records, and confirm in writing that it has done so.

12.4 Termination shall not affect any accrued rights or liabilities of either party.

13. LIABILITY

13.1 Nothing in these Terms and Conditions limits or excludes Aura Media Group's liability for:

(a) fraud or fraudulent misrepresentation;

(b) death or personal injury caused by negligence;

13.2 Subject to clause 13.1, Aura Media Group shall not be liable for any loss of profits, loss of business, loss of anticipated savings, loss of data, or any indirect, special or consequential loss or damage arising from the supply or use of the Data.

13.3 Aura Media Group's total aggregate liability arising out of or in connection with any Order Confirmation shall not exceed the total Fees actually received by Aura Media Group from the Buyer in the 12-month period preceding the relevant claim.

13.4 The Buyer's sole recourse against Aura Media Group in respect of Data quality is the investigation and remedy procedure set out in clause 8. The Buyer shall not institute proceedings for breach of these Terms and Conditions more than one year after the date on which it became aware, or ought reasonably to have become aware, of the relevant breach.

13.5 The Buyer shall indemnify and hold Aura Media Group harmless from and against any losses, claims, costs, penalties and expenses arising from:

(a) any breach by the Buyer or any End User of these Terms and Conditions;

(b) any breach by the Buyer or any End User of Data Protection Laws in connection with their use of the Data;

(d) any regulatory investigation or enforcement action arising from the Buyer's use of the Data.

14. GENERAL

14.1 These Terms and Conditions shall be governed by and construed in accordance with English law. The courts of England and Wales shall have exclusive jurisdiction.

14.2 No variation to these Terms and Conditions shall be effective unless agreed in writing by Aura Media Group.

14.3 The Buyer may not assign its rights under any Order Confirmation without the prior written consent of Aura Media Group. Aura Media Group may sub-contract any of its obligations, provided that where it does so, Aura Media Group shall remain responsible for the performance of those obligations.

14.4 If any provision of these Terms and Conditions is held to be invalid or unenforceable, the remaining provisions shall continue in full force.

14.5 No failure or delay by Aura Media Group to exercise any right or remedy shall constitute a waiver of that or any other right or remedy.

14.6 Any notice given under these Terms and Conditions shall be in writing and shall be sent by registered post, recorded delivery, or email with proof of sending to the addresses set out in the Order Confirmation. Notices sent by post shall be deemed received 48 hours after posting. Notices sent by email shall be deemed received on the next Business Day after transmission.

14.7 A person who is not a party to an Order Confirmation shall have no rights under the Contracts (Rights of Third Parties) Act 1999 to enforce any term of these Terms and Conditions.

14.8 These Terms and Conditions, together with the relevant Order Confirmation, constitute the entire agreement between the parties relating to the supply and use of the Data and supersede all prior discussions and agreements.

Aura Media Group Limited | Breakspear Park, Breakspear Way, Hemel Hempstead, HP2 4TZ
Company Registration No. 11239047 | ICO Registration No. ZA324659
Regulated by the Financial Conduct Authority (FCA) | FRN 835708
info@auramediagroup.co.uk | 01442 345005
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