Last updated 08/01/2022
Tindle Newspapers Limited ("Tindle Newspapers", "we", "our" or "us") is the data controller of your personal data. We may collect, use, share and disclose or otherwise process your personal data in line with this privacy notice. Our contact details are The Old Court House. Union Road, Farnham, Surrey, GU9 7PT [email protected].
How we collect your personal data
We collect your personal data when you provide it to us. For example, when you complete an online form, subscribe to one of our publications, contact us with a story or lead, register (create an account) to leave comments or use one of our services, enter a competition or subscribe to our newsletter. This may also include any information you may provide when accessing our social media sites. You are responsible for any personal information about yourself or others that you post on our social media pages and forums. You should be aware that this data is accessible by third parties and may be copied and used by those third parties.
The data we collect about you
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).
We may collect, use, store and transfer (process) different kinds of personal data about you which we have grouped together follows:
Identity Data includes your name, username or similar identifier, title, date of birth, IP address and social media identifier.
Contact Data includes billing address, delivery address, email address and telephone numbers.
Your views and opinions this will be in relation to stories you have contacted us about and your comments on news stories and forums.
Financial and Transactional Data includes bank account and payment card details and information about payments to and from you and other details of products and services you have purchased from us.
Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our website.
Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback, comments and survey responses.
Usage Data includes information about how you use our website, products and services.
Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We may also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity.
How we use your personal data
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract we are about to enter into or have entered into with you, for example when you have subscribed to one of our publications or registered and created an online account to allow you to comment on news articles and forums.
Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests. This may be to send you information about your subscription, the services you use, when you contact us with a news story and to send you marketing and user surveys.
Where we need to comply with a legal or regulatory obligation.
Generally we do not rely on consent as a legal basis for processing your personal data. However, in some circumstances we may use consent to send marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.
For journalistic purposes, data will be used for the researching, compiling and publishing of articles in print and online. Such information will need to be retained for legal reasons, for follow-up articles, for a paper trail for correspondence, for points of contact, and for other reasons associated with the running of a newspaper and its associated website.
Articles will be published on our website. Published newspapers are also stored in libraries and our e-editions of newspapers are stored through our websites. Commercial and editorial information will be stored on computers, on servers, on phones and in the cloud, all of which will be password-protected. Some information will also be stored in notebooks which will be securely locked away or kept safe when away from the office.
We will review the information from time to time to ensure it’s still relevant and up-to-date and delete any we no longer need. If asked, we will be able to show that this is being done.
We will keep personal information only as long as it is necessary and only as much as is necessary.
Accuracy: For journalistic work, we follow the IPSO Code of Conduct to ensure compliance with the GDPA.
We will be able to show that we have taken reasonable steps to check facts and record personal information correctly. If the published story, in print or online, is later shown to be inaccurate, records will be updated to avoid repetition and online archives will have a correction attached. Where the information has been passed to a third party (such as SWNS) we will make sure that they are informed of the inaccuracy.
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
Promotional offers from us
We may use your identity, contact, technical, usage and profile data to form a view on what we think you may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).
You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company outside Tindle Newspapers for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by logging into their website and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you or by contacting us any time.
Where you opt out of receiving these marketing messages, this will not apply to service communications, for example in relation to a subscription or other transactional processing.
We do not transfer your personal data outside the UK or European Economic Area (EEA).
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. Where we use data processors, we undertake checks to ensure they are compliant with data protection legislation.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.
By law we have to keep basic information about our customers (including contact, identity, financial and transaction data) for six years after they cease being customers for tax purposes.
In some circumstances you can ask us to delete your data: see “Request erasure” below for further information.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
Your legal rights
You have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request. You should be aware that this is not an absolute right.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
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If you feel we haven’t handled your data properly we would always ask that you contact us first. You can email us at [email protected].
If you still feel unhappy about how we have processed your data you have the right to raise your concerns with the Information Commissioners Office (ICO). The ICO are the UK data protection regulator. You can find their contact details on their website https://ico.org.uk/