Privacy & Cookies Policy (the “Policy”)
What this Policy is for?
This Policy explains how we protect and handle any information you provide to us, including via our websites, mobile apps, communications by email and through social media, by telephone and in person. It also covers any information we receive from third parties. It also provides you with an overview of the rights you can exercise regarding what we do with your information.
By using our products and services, including browsing our websites, registering or logging in, we may use your information as outlined in this Policy.
What kinds of information do we collect:
- Information you’ve provided to us:
We collect information about you when you provide it to us, including when you create an online account, subscribe to one of our titles, respond to one of our promotions, order or register your interest in one of our products, or post a comment under an article. This could be via your computer browser, via an app, by telephone, or by post.
- Information from your device:
We collect information from and about the device you are using when you interact with one of our websites, apps or other products/services, including adverts. This may include:
- Device Type: Information about your operating system, hardware, software, browser type in order to tailor the experience to your device (e.g. screen resolution).
- Device Operations: Information about your operations and behaviors performed on your device to tailor the experience based on how you or similar users have interacted with our content.
- Unique identifiers: device IDs in order to save your preferences against an identifier to refer to on subsequent pages.
- Device Settings: Information from your device’s setting such as access to your GPS location/Information related to the location of your device so that we know which version of the website to serve you;
- Network/connections: Your IP address, so that we can recognize if you have visited us before and allow your device to communicate with our websites and apps.
- Information about transactions made If you purchase anything or make any other financial transactions on any of our websites/apps, we collect information about your purchase and ask for information including your name, e-mail address and delivery address to be forwarded on to the vendors who are responsible for delivering your order. This does not include payment information such as your credit/debit card number.
- Information from partners Where you have registered or created an account with one of our websites, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you. For more information about this, please see “Personalization/Identifying Your Interests” in Section 2 below.
- Information about other people By supplying us with information about someone else, you confirm that they have authorized you to provide us with their information (including sensitive personal data) on their behalf.
Before you use “email a friend” or “share this article” buttons please make sure that anyone you wish to email or share with are happy for this to occur and expect to receive the email or article. You may only share the details of another person with us where you have their express permission.
How we may use your information
- Delivering services
By using our websites, apps and other products and services, we may process your information for the purpose of providing you with such products and services and managing our relationship with you, which shall include (without limitation):
– communicating with you in relation to your account or service, service updates or other non-marketing communications;
– dealing with, and responding to you about a comment you have submitted for or on our message boards, blogs and other such user-generated content facilities;
– ensuring the integrity of votes, competitions and polls;
– maintaining records of our communications with you if you get in contact with us;
– obtaining customer reviews and conducting market research.
Legal basis for these processing activities: Legitimate Interests
– running competitions effectively and informing you if you have been successful in any competitions or promotions;
Legal basis for this processing activity: Contract
- Communicating with you
In accordance with your preferences and data protection legislation, we may use your information to send you direct marketing communications. This may include communications by post, telephone, email, Whats App or SMS about our products and services, events and special offers. We may also send you periodic newsletters about your chosen services, inform you of promotional offers that you might find interesting, and inform you about the any changes to our products and services where we have permission to do so.
Legal basis for processing this data: Consent/Legitimate Interests
- Personalization/Identifying your interests
Legal basis for this processing activity: Legitimate Interests
- Tailored advertising
- Location based services and advertising
Where we provide services that utilize your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or Wifi on mobile devices) where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our websites/apps. Where you have granted permission to access your device’s location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.
- Measurement and analytics
We may use certain information (such as the websites that you visit and advertisements you see or click on) to help advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.
Legal basis for this processing activity: Legitimate Interests/Consent
- Improving our services and products
We may use your information to monitor and improve our products, content and services. This may include (without limitation): – developing the design and style of our products and services to make improvements – carrying out statistical, technical and logistical analysis to inform our strategic development – blocking disruptive use and ensuring the security of our products and services If you have registered on our websites or apps, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.
Legal basis for this processing activity: Legitimate Interests
- Message boards, blogs and other public forums
Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information.
Legal basis for processing this data: Consent
Legal basis for processing this data: Legitimate Interest
Legal Bases for processing your data
Contract: We process some of your data as a necessary part of performing our contractual obligations to you. For example, ensuring products you buy can be delivered to you.
Consent: Some processing activities will only be done where we have sought your prior consent. If we require your consent, we will provide you with full details of the information that we would like and the reason we need it. Once given, you have the right to withdraw your consent again at any point and we will be obliged to stop processing your data and delete it unless we can demonstrate that another legal basis applies.
Legitimate Interests: We process some of your data because it is in our Legitimate Interests to do so. Where this is the case, we have considered the impact using your information may have on you and limited our use to only what is strictly necessary. Where we are using this as our basis, we can provide you with an explanation of why the processing is in our interests and you are free to contest this decision if you wish.
How we may share your information
- Sharing with third-party partners
Vendors: Promotions: Sometimes we bring you promotions in association with other companies. If you enter such promotions, the other company will use the information you submit and we provide to them as a data controller in line with their own privacy policies. Affiliates: We regularly partner with industry affiliates to bring you special deals on products and packages you may find of interest. These providers collect marketing permissions for us and share data back with us about your purchases in order for us to measure the effectiveness of our marketing campaigns.
This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you.
Marketing personalization: We can only obtain this information where they have your permission to share this information with us in line with their privacy policies. You can opt-out of having your personal information profiled in this way by contacting us or adjusting your account settings.
Sampan Media may, use and share, within that group, the information you provide and other information held about you for the purposes set out in this Policy. We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
Details of transfers to third countries and safeguards
Any organization that has access to your information in the course of providing services on our behalf will be governed by contractual restrictions to make sure they protect your information and comply with applicable data protection legislation.
How can you exercise your rights under the GDPR
- Access: If you wish to exercise your right to access a free copy of your data, you can contact us at the contact details provided below at Section 12.
- Deletion: To ask us to delete your personal data, please contact us at the contact details provided below at Section 12. However, there may be circumstances where we are legally entitled to retain it.
- Rectification: If you wish to update or rectify your data, you can do this by contacting us.
- Revoke consent: If you wish to object to the processing of your data for direct marketing or online behavioral advertising purposes, you can opt-out by updating your settings or, for direct marketing, clicking on the “unsubscribe” link in any marketing email or newsletter you receive from us.
- Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalization purposes you can adjusting your account settings or contact us directly.
- Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us as at the contact details provided below stating the nature of and reasons for such objection. If you are contacting us to exercise any of your rights under the GDPR, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.
Data retention and account deletion
We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a case by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account we still have to retain some data for fraud prevention purposes and financial auditing and legal liability for any comments posted or otherwise.
Children & young people
Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 18. If you are under the age of 18, we request that you do not provide us with your information and do not use our websites and apps. If you are a parent or guardian of a child under 18, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time. In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.
When you use our websites and apps we may collect information using cookies or similar technologies. What are cookies and how do they work? Cookies are small files that are downloaded to your computer or mobile device when you visit a website. Your browser sends these cookies back to the website every time you visit the site again, so it can recognize you. This allows websites to tailor what you see on the screen.
Do you use other technologies which are similar to cookies?
Yes, we use the following:
- Web beacons: Our websites, apps and emails often contain small invisible images known as ‘web beacons’ or ‘tracking pixels’. These are used in a way similar to cookies to:
– understand when a particular part of a webpage, email or app is viewed,
– understand how successful an article or an email marketing campaign has been
– verify any clicks through to links or advertisements contained in emails
- Flash cookies: In certain situations, we use Adobe Flash Player to deliver video clips. Local Shared Objects (Flash cookies) are used to provide functions such as remembering your settings and preferences.
- Tracking URLs: These are web links that allows us to measure when a link is clicked on. They help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
- Device identifiers: We use device identifiers on mobile devices in the same way as cookies are used on web browsers. A device identifier is a unique number on your device which allow us to remember your device.
Cookies and other online tracking technologies are an important part of the internet. They make using websites much smoother and affect lots of the useful features of websites.
There are many different uses for cookies, but for within our sites, they fall into the following groups:
- Cookies that are needed to provide the service you have asked for (Essential) Some cookies are essential so you can move around our websites and use their features. Without the use of these cookies parts of our websites would not function.
- Cookies that collect information about your choices and preferences (Functional / Preference) These cookies collect information about your choices and preferences, and allow us to remember things like:
- Cookies used to understand how people use our products and services (Analytics) We use analytics cookies to gather information about what pages, links and sections of our apps are popular and which ones don’t get used so much to help us keep our sites relevant and up to date. They are also useful to be able to identify trends of how people navigate our sites so we can identify improvements to make to the customer journey We may combine information collected by analytics cookies with other information that you provide to us. For instance, if you have registered for an account with us, we may combine your contact details other information you provide us with the browsing history from your device collected by analytics cookies (including data collected from before you registered and when you are signed-out).
We may also use this combined information to improve our products and services. For instance, we may analyse this information in aggregate to improve our advertising systems.
- Cookies used to show advertising that is relevant to you (Tracking and Advertising) Some advertising, known as “online behavioral advertising” is tailored to you and uses information collected by first party and third-party cookies based your web browsing activity. Cookies are placed on your browser to remember the websites you have visited. Advertising based on what you have been looking at is then displayed to you when you visit websites who use the same advertising networks.
To help us deliver relevant advertising using cookies, we use Google Double Click. Click here to find out more about Google Double Click. We also use these cookies in order to:
- know how many advertisements we serve, how many times these are clicked or hovered over with a mouse cursor, how many advertisements we show to a given user and how many customer actions these generate.
- understand which customers reach a sale or other action page on an advertiser’s site. This allows us to monitor how many sales or actions we achieve for an advertising client, and therefore, how effective our advertising is.
- protect our advertisers’ brands, we often use a technology that scans the page to ascertain that it is safe from profane, sensitive & potentially brand-negative topics, before serving an ad there. This process is called “ad verification”.
You can change your cookie settings on this website at any time via your Privacy Settings.
Cookies can also be controlled using the following instructions:
- Mobile Devices: When using a mobile device, you can opt-out of receiving online behavioral advertising by selecting ‘Limit Ad Tracking’ in the Settings of your Apple iPhone or iPad, or the “Opt out of interest-based ads” in the Settings on your Android device. You may also be able to reset your unique identifier used for online behavioral advertising (referred to as an “Advertising ID”) in the Settings on your Apple or Android device.
- Web-Beacons: You can usually prevent the operation of web-beacons by changing your web-browser cookie settings and your ad choices, or for those in emails, by switching off images in your email client or viewing emails using only the “text” display (rather than “HTML” display”). See the “Help” section of your email client for instructions. Please see the All About Cookies website for further information about managing your options.
- Flash Cookies: You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website.
- Browsers: The links below take you to the help sections for each of the major browsers that will tell you how you can manage your cookies:
– Internet explorer
– Safari OS X
– Safari iOS
– Windows phone
Please note that our website, apps and other products and services may not work correctly (or at all) if you change certain preferences. For example, you may not be able to purchase products via our websites. However, you may still be able to place an order via our telephone order line. Where you use our apps, similar technologies to cookies are used for analytics. It is not presently possible to opt-out of these similar technologies. If you are not happy to be included in our analysis, please do not use our apps.
Please also note that after applying these settings, you will continue to receive advertising, however, it may not be tailored to your likely interests using information collected from cookies and similar technologies on your device.
Updates to this Policy
We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.
How to contact us:
If you have any queries or comments about this Policy or to exercise any of your rights under the GDPR, please contact us by email at: