This privacy notice is for visitors to our websites, apps and other digital platforms. It sets out how we use personal data that we hold about you and gives information on how to exercise your legal rights. In this notice ‘we’ and ‘our’ means The Enfield Media Group LLC which operates this platform.
Personal data can include:
• Your name, address, year of birth or title
• Debit or credit card details
• Information about your devices, such as IP address
• How you browse our websites
• Details of products or services you purchase
What data do we process about our visitors?
If you register for an account on our website in order to comment on an article, enter a competition or receive selected newsletters, you will need to provide us with your full name, email address, year of birth and postcode.
If you plan to comment on our website you will need to provide us with a commenting name.
If you are subscribing to one of our paid-for subscription products, in addition to your name, email address and year of birth, you will also need to provide your billing address and payment card information. This information may also be collected also if you attend one of our ticketed events.
If you attend one of our events remotely, we may share your name and contact details with the platform hosting the event.
If you contact our Customer Services team, we will need your name and contact information as well as full details of your query.
The data these companies might hold about you is collected from publicly available records, such as the electoral roll, or from other sources where you have agreed for your information to be shared with third parties.
We may check our database of registered users against the information they hold on their systems to see if there are any matched individuals. If there is a match, we can collect and store some of this additional information (which may include statements about your lifestyle and interests) in our database and use it to further enhance our understanding of the types of products and services you might be interested in.
We may also match your cookie data with this third party data, and aggregate this data into interest-based segments or profiles which we use to develop our products, or serve you more relevant advertising. Sometimes we share these segments with other publishers so they can show you advertising on their websites. We can also pool these segments with those from other publishers so that advertisements can be shown across multiple websites to readers whilst limiting the number of times you see the ads.
We can also access information from social media activity such as when you ‘like’ the website, share content or follow us on Twitter. When you sign in to the website using social media you grant permission to the social network to share some of your details with us. Depending on the network this will include basic account information such as name, email address, date of birth and any other details you choose to share according to your particular social media account settings.
We may also collect information about third party products and services which you purchase after visiting the Website. For example, when you use a voucher code or click on a link to an advertiser’s site.
What do we use this data for?
We also log and use information about any service errors or interruptions that you have experienced in order to help us create fixes and to make technical improvements to our website
How we may contact you
From time to time we may contact you by email or push notification to give you service information. For example if your subscription is coming to an end, or your payment method has expired.
If we have your permission we may also send you newsletters or emails about our events, subscription benefits or offers.
Occasionally we may ask you if you would like to participate in market research, or respond to you if you have made a complaint or have logged a query.
What is our legal basis for processing personal data?
We will only use your personal data for advertising and marketing, personalization of content and services, analytical purposes (such as, understanding who our readers are and how they browse our websites) and to track eCommerce purchases if we have your specific consent to do so. This includes the use of data provided by you and our partners for profiling purposes in order to generate revenue from you so we can improve our products and services.
If you have given us consent to send you specific newsletters, you can unsubscribe from these at any time by clicking unsubscribe at the bottom of each email, or by logging into your account and managing your email preferences.
The legitimate interest pursued by us to analyze our website traffic in order to maintain the service, for example monitoring successful page loads or error messages.
Performance of a contract
When you purchase a subscription or buy another product or service from us, we will need to process your details in order to supply the item to you (for example, to deliver a product to your home, we would need to use your name and address).
How can you access and update your personal information?
If you are a registered user or subscriber, you can update your personal information by signing in to your account page or through your social network provider. In all other cases, please contact customer services.
You can ask for a copy of the personal information we may hold about you, or for your data to be deleted via customer services.
How long do we keep your personal information for?
We will keep your information only for as long as it is relevant and useful for the purpose for which it was originally collected.
Please note that if your account appears to have not been used for 12 months, we will try and contact you to check whether it is still in use and/or we will delete it. Please note that any comments associated with your account will also be deleted.
If you do not read the newsletters that you have subscribed to, we will suppress your name from the relevant list after 6 months.
If you do not complete a social registration the data you entered as part of that registration will be deleted within 24 hours. Data from any other incomplete registration or subscription attempt will not be stored.
If you purchased a subscription, we will retain your data for at least 12 months after your subscription ends in case there are any outstanding billing or other customer service issues.
A record of a customer service query is retained for at least three years from the date it was submitted to us.
We retain cookie data and corresponding third party data for 13 months from when it was collected from your device.
We may need to retain your data for a longer period if there is a legal claim or if we are required to so by any regulation.
Who will we share your personal information with?
Advertisers and advertising networks sometimes require data to select and serve relevant advertisements to you and others. We may provide them with aggregate cookie information about our users with certain attributes (for example, we may inform them that 500 men aged under 30 have clicked on their advertisement on any given day). We may also use such aggregate information to help advertisers reach the kind of audience they want to target (for example, women in the UK who are interested in travel).
We share cookie data with other publishers via a secure data management platform when advertising campaigns are served across multiple news websites. These publisher partners are not able to access this data themselves, only serve the advertisements across their own websites to readers whose cookie data form part of the selected advertising segments.
We reserve the right to disclose your personal information to comply with applicable laws and government or regulatory bodies’ lawful requests for information.
Your personal details may be shared with third party organizations we have contracted to provide services to us which include processing data. For example, to send you the emails you have signed up for. Only companies who can provide adequate safeguards will be used to ensure your data is stored and handled securely.
We may also have to release information because of a legal requirement on us or pursuant to a court order.
We may transfer, sell or assign any of the information described in this Privacy Notice to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
Using children’s personal data
We do not aim our services to children under the age of 13. We do not allow children under 18 to register an account with us.
Will your data be sent overseas?
As you will know, the internet does not recognize national boundaries. Services on the web are accessible globally so collection and transmission of personal data is not always confined to one country.
You should be aware that by using the website and those of our partners or any website we link through to, your personal data may be processed in or transferred to other countries, the USA for example, and you agree to your personal data being transferred or processed in this way.
Your personal data will only be stored or transferred within the UK, EU or US under the EU-US Privacy Shield, or using other safeguards that have been approved by the relevant regulatory body.
Right of access – you have the right to request a copy of the data that we hold about you.
Right of rectification – you have a right to correct data that we hold about you that is inaccurate or incomplete.
Right to be forgotten – you can ask for the data we hold about you to be erased from our records.
Right to restriction of processing – you can ask for us to restrict the way we process your data.
Right of portability – you have the right to have the data we hold about you transferred to another organization.
Right to object – you have the right to object to our processing your data where we are relying on a legitimate interest in order to process it.
Right to withdraw your consent – you have the right to withdraw your consent at any time.
Please note that these rights are not absolute and certain exemptions apply.
What are cookies?
For almost any modern website to work properly, it needs to collect certain basic information on its users. To do this, a site will create files known as cookies – which are small text files – on its users’ computers, tablets or mobile devices. These cookies are designed to allow the website to recognize its users on subsequent visits, or to authorize other designated websites to recognize these users for a particular purpose.
Cookies do a lot of different jobs which make your experience of the Internet much smoother and more interactive. For instance, they are used to remember your preferences on sites you visit often, to remember your user ID and the contents of your shopping baskets, and to help you navigate between pages more efficiently. They also help ensure that the advertisements that you see online are more relevant to you and your interests. Some data collected is designed to detect browsing patterns and approximate geographical location to improve user experience.
We collect a number of cookies from our users for various reasons, not least to track our own performance – but also to let us serve you content tailored to your own specifications, hopefully improving your overall experience of the website. The cookies we use allow users to register to make comments, allow us to calculate how many visitors we have and how long they stay on our site.
We believe that your experience of the site would be adversely affected if you opted out of the cookies we use.
What types of cookie are there and which ones do we use?
There are two types of cookie:
Cookies also have, broadly speaking, four different functions and can be categorized as follow: ‘strictly necessary’ cookies, ‘performance’ cookies, ‘functionality’ cookies and ‘targeting’ or ‘advertising’ cookies.
Strictly necessary cookies are essential to navigate around a website and use its features. Without them, you wouldn’t be able to use basic services like registration or shopping baskets. These cookies do not gather information about you that could be used for marketing or remembering where you’ve been on the internet.
Examples of how we use ‘strictly necessary’ cookies include:
• Setting unique identifiers for each unique visitor, so site numbers can be analyzed.
• Allowing you to sign in to the website as a registered user or subscriber.
Performance cookies collect data for statistical purposes on how visitors use a website, they don’t contain personal information such as names and email addresses, and are used to improve your user experience of a website.
Information supplied by performance cookies helps us to understand how you use the website; for example, whether or not you have visited before, what you looked at or clicked on and how you found us. We can then use this data to help improve our services. We generally use independent analytics companies to perform these services for us and when this is the case, these cookies may be set by a third party company (third party cookies).
If you have registered with the website we can combine the data from the web analytics services and their cookies with the information you have supplied to us, so that we can make your experience more personal by recommending certain articles to you based on your reading behavior or tailoring your emails with content you might find more interesting. We would only do this if you have given us permission to communicate with you. Sometimes the data used from the web analytics companies has been collected before you registered or signed in. In these cases, if we use this data to identify you, we use it only in accordance with our privacy notice.
Functionality cookies allow users to customize how a website looks for them: they can remember usernames, language preferences and regions, and can be used to provide more personal services like local weather reports and traffic news.
How do I manage my cookies?
You should be aware that any preferences will be lost if you delete all cookies and many websites will not work properly or you will lose some functionality. We do not recommend turning cookies off when using our website for these reasons.
Most browsers accept cookies automatically, but you can alter the settings of your browser to erase cookies or prevent automatic acceptance if you prefer. Generally you have the option to see what cookies you’ve got and delete them individually, block third party cookies or cookies from particular sites, accept all cookies, to be notified when a cookie is issued or reject all cookies. Visit the ‘options’ or ‘preferences’ menu on your browser to change settings, and check the following links for more browser-specific information.
If you choose not to receive our cookies, we cannot guarantee that your experience will be as fulfilling as it would otherwise be. For instance, the site won’t be able to recognize your commenter ID, meaning that you won’t be able to leave comments.