Everything that we do is guided by our values– including how we use data.
We use your personal data for many reasons, from understanding how our users engage with our videos to inform our marketing and advertising. Ultimately, this allows us to publish the videos that you see on our sites and apps.
These are the main reasons why we collect and use data about our users:
- To show you videos that are relevant to you and to improve your experience on our site
- To provide the services you sign up for, such as subscriptions
- To carry out marketing analysis and send you communications when we have your permission, or when permitted by law
- To enable us to show advertising on our sites.
We think carefully about our use of personal data, and below you can find the details of what we do to protect your privacy. This policy covers, among other topics :
- Information about your rights and our obligations
- Clarity about our dealings with you and transparency about how we collect and use your personal data
- Commitments on how we protect your personal data
- Commitments on how we will facilitate your rights and respond to your questions.
Personal data is any information about you by which you can be identified. This can include information such as:
- your name, date of birth, email address, postal address, phone number, mobile number;
- debit card details;
- information about your device (such as the IP address, which is a numerical code to identify your device that can provide information about the country, region or city where you are based); and
- information relating to your personal circumstances and how you use our sites, apps and services.
What personal data we collect and how we use it
We collect personal data when you sign up for our services and when you browse our sites or use our apps. This information is used to provide our content and other services, display advertising and analyse how visitors use our sites or apps.
When you sign in to our sites or apps using your Facebook login details, you give permission to Facebook to share with us your email address and certain aspects of your Facebook profile if you have made these public on your Facebook profile. This only includes your first and last name, age range, link to your Facebook profile and profile picture. We do not have access to updates on your Facebook profile. If you use your Google login details, you give Google permission to share the information that you have made public in your Google profile. This only includes your first and last name, your email address and whether your email address has been validated, your age range, a link to your Google profile and, if you have one, your profile picture.
How we collect personal data
We collect personal data when you:
- pay for a subscription or purchase any other products/services;
- attend our events;
- enter our competitions and surveys;
- sign up to our editorial emails;
- post in our online community;
- sign up for marketing communications;
- use mobile devices to access our content;
- access our sites, through cookies and other similar technology; and
- when you contact us via email, social media, our apps or similar technologies or when you mention us on social media.
Why we use your personal data
We use personal data collected through our sites and apps for a number of purposes, including the following:
- To provide the services you sign up for, such as sending out subscriptions. We also use the personal data for related internal administrative purposes - such as our accounting and records - and to make you aware of any changes to our services.
- To send marketing communications when we have your permission, or when permitted by law.
- To carry out marketing analysis, for example we look at what you have viewed on our sites and apps and what products and services you have bought (including what you have looked at and what products or services you have bought on our other platforms) to better understand what your interests and preferences are, and to improve our marketing by making it more relevant to your interests and preferences. You can opt out from having your personal data used for marketing analysis by going into your account to the tab “Emails and marketing”.
- To improve our marketing communications, we use a similar technology to cookies to confirm whether you have opened a marketing email or clicked on a link in the email.
- For statistical purposes such as analysing the performance of our sites and apps and to understand how visitors use them.
- To respond to your queries and to resolve complaints.
- To comply with applicable laws and regulations.
Legal grounds for using your personal data
We will only use your personal data where we have a legal ground to do so. We determine the legal grounds based on the purposes for which we have collected and used your personal data. In every case, the legal ground will be one of the following:
- Our legitimate interests: Where it is necessary for us to understand our readers, promote our services and operate our sites and apps efficiently for the creation, publication and distribution of news, media and related journalistic content both online and in print form, globally. For example, we will rely on our legitimate interest when we analyse what content has been viewed on our sites and apps, so that we can understand how they are used. It is also in our legitimate interest to carry out marketing analysis to determine what products and services may be relevant to the interests of our readers. You can opt out from having your personal data used for marketing analysis in your account in the “emails and marketing” tab.
- Performance of a contract with you (or in order to take steps prior to entering into a contract with you): For example, where you have purchased a subscription from us and we need to use your contact details and payment information in order to process your order and deliver your subscription.
- Compliance with law: In some cases, we may have a legal obligation to use or keep your personal data.
Updating your personal data and your profile page on our sites
You may also update your marketing preferences in the “Emails and marketing” tab in your account.
Personal data that we receive about you from other organisations
Adding to or combining the personal data you provide to us
When you sign up to our services we may add to the personal data you give us by combining it with information shared with us by other trusted organisations. This includes, for example, information about the region that you are located in, so that we can show you the prices for subscriptions or other products in your local currency. We may also add information to improve the accuracy of your delivery address when we send out mail. We may also obtain information from partners whose offers we include in some of our marketing communications and we use this information to ensure that we do not send you irrelevant marketing.
Using children’s personal data
We do not aim any of our products or services directly at children under the age of 13 and we do not knowingly collect personal data about children under 13. Some of our services may have a higher age restriction and this will be shown at the point of registration.
Security of your personal data
We have implemented appropriate technical and organisational controls to protect your personal data against unauthorised processing and against accidental loss, damage or destruction. You are responsible for choosing a secure password when we ask you to set up a password to access parts of our sites or apps. You should keep this password confidential and you should choose a password that you do not use on any other site. You should not share your password with anyone else, including anyone who works for us. Unfortunately, sending information via the internet is not completely secure. Although we will do our best to protect your personal data once with us, we cannot guarantee the security of any personal data sent to our site while still in transit and so you provide it at your own risk.
Who we share your personal data with
We do not share your personal data with other people or organisations that are not directly linked to us except under the following circumstances:
- We may share your data with other organisations that provide services on our behalf such as dealing with online payments and other forms of payment processing, ie credit card transactions and preventing fraud.
- We may also share your data with our advertising partners, as set out in the section about Online Advertising below.
- We may reveal your personal data to any law enforcement agency, court, regulator, government authority or other organisation if we are required to do so to meet a legal or regulatory obligation, or otherwise to protect our rights or the rights of anyone else.
Any organisations which access your data in the course of providing services on our behalf will be governed by strict contractual restrictions to make sure that they protect your data and keep to all data privacy laws that apply. We may also independently audit these service providers to make sure that they meet our standards.
We will not share your personal data with anyone else for their own marketing purposes unless we have your permission to do this.
Some of our webpages use social plug-ins from other organisations (such as the “Facebook Recommend” function, Twitter’s retweet function, Google+ function). These other organisations may receive and use personal data about your visit to our sites or apps. If you browse our site or view content on our apps, information they collect may be connected to your account on their site. For more information on how these organisations use personal data, please read their privacy policies.
International data transfers
Whenever we transfer your personal data out of the European Economic Area (EEA), we ensure similar protection and put in place at least one of these safeguards:
- We will only transfer your personal data to countries that have been found to provide an adequate level of protection for personal data.
- We may also use specific approved contracts with our service providers that are based in countries outside the EEA. These contracts give your personal data the same protection it has in the EEA .
- Where we use service providers in the United States, we may transfer personal data to them if they are part of the Privacy Shield scheme, which requires them to provide a similar level of protection of your personal data to what is required in the EEA.
If you are located in the EEA, you may contact us for a copy of the safeguards which we have put in place for the transfer of your personal data outside the EEA.
How long we keep your personal data
How we may contact you
If you have raised a query or a complaint with us, we may contact you to answer your query or to resolve your complaint.
Cookies and similar technology
When you visit our sites or when you use our apps, we may collect personal data from you automatically using cookies or similar technology. A cookie is a small file that can be placed on your device that allows us to recognise and remember you.
Advertising on our sites that is based on cookies and similar technology
When you browse our sites or use our apps, some of the cookies and similar technology we place on your device are advertising cookies, so we can understand what sort of pages you are interested in. We can then display advertising on your browser based on these interests. For instance if you have been reading a lot of food and drink articles, we may show you more advertisements for food and drink.
We do not collect or use information such as your name, email address, postal address or phone number for personalised online advertising.
Online retargeting is another form of online advertising that allows us and some of our advertising partners to show you advertising based on your browsing patterns and interactions with a site away from our sites.
For example, if you have visited the website of an online clothes shop, you may start seeing adverts from that same shopping site displaying special offers or showing you the products you were browsing. This allows companies to advertise to you if you leave their website without making a purchase.
Your rights with regard to the personal data that we hold about you
You can contact us with regard to the following rights in relation to your personal data:
- If you would like to have a copy of the personal data we hold on you or if you think that we hold incorrect personal data about you, please email us: firstname.lastname@example.org. We will deal with requests for copies of your personal data or for correction of your personal data within one month. If your request is complicated or if you have made a large number of requests, it may take us longer. We will let you know if we need longer than one month to respond. You will not have to pay a fee to obtain a copy of your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive.
- Where you have provided us with consent to use your personal data, you can withdraw this at any time.
- Where applicable, you may also have a right to receive a machine-readable copy of your personal data.
- You also have the right to ask us to delete your personal data or restrict how it is used. There may be exceptions to the right to erasure for specific legal reasons which, if applicable, we will set out for you in response to your request. Where applicable, you have the right to object to processing of your personal data for certain purposes.
If you want to make any of these requests, please contact email@example.com
We may need to request specific information from you to help us confirm your identity.