Privacy Notice

Introduction

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 Independent Digital News and Media Limited 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.

If you sign a petition on independent.co.uk we will collect your name and email address, and a disclosure to state you are over 18. We do not direct our service to people under the age of 18, and we do not knowingly collect personal information about them.

Your name will be shared with the recipient of the petition. Once shared we are unable to delete your details from the petition, so please do not sign it if you are unsure you would like your data to be shared in this way.

Your data will be stored with our contracted partner, which may mean transferral to the US. You should be aware that this will happen using approved UK Standard Contractual Clauses for data transfers or other similar safeguards that have been approved by the relevant body.

If any special category data is collected, for example related to political beliefs, we will delete this data within 3 months after the petition has closed.

You will be given the opportunity to opt in for further communications about the petition you have signed, or to receive emails from us related to updates or events at The Independent. We will process the data you give us under consent.

We collect data about our website’s visitors using technology such as cookies, device IDs, IP addresses and location data. This can include information about your location, the type of device you are using and your online browsing history. If you would like to know more about our use of cookies and how to manage them, please read our Cookie Notice.

Sometimes we obtain additional information about you from third parties. At present, we receive information from the following reputable suppliers: Skimlinks, Eyeota, Bombora, Experian, Quantcast and Nielsen.

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.

With your consent, we will share your IP address and first party cookie with Experian who will use it to carry out data profiling by linking your IP address and first party cookie with their own IP address database, and in turn, to one or more of the “predictive models” they have created. Experian’s predictive models are created using data from various data sources (including public data sources) and are used to try to predict behaviour and preferences (e.g. how likely you are to buy a holiday online or take a particular type of holiday) or likely circumstances (e.g. Experian’s model might predict you are a city dweller and therefore less likely to be interested in gardening).

Experian will not share the details we provide to them about you with any third party but will use and store it primarily to help:

• us better understand the likely characteristics of visitors to our website(s);

• us improve the relevancy and appropriateness of the advertisements we display to you when you visit our website(s); and

• Experian to link identifiers with the same IP address together for the purposes of applying their predictive models

To understand more about the use of your data by Experian, including which lawful basis Experian relies on to process your personal data and how to exercise your data protection rights in relation to their use of your data (including how to opt-out), please click through to the Experian website at https://www.experian.co.uk/marketing-services/consumer-information-portal

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?

* Verifying your identity (for example when you return to the website and have already logged in).

* Personalising the advertising you see on the website so that it is more relevant to you. For more information on how we use your cookie data please see our Cookie Notice.

* Improving the design and style of the website.

* Informing you about products, services or promotional offers that you might find interesting if you have chosen to receive these type of communications.

* Sending you service messages about your subscription or account registration, for example if you have clicked a password reset link. This could be by email, overlay on the website or push notification.

* 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.

* Enabling you to share our content with others using social media or email.

* Communicating (and personalising such communication) with you through our newsletters, but only those you have consented to receive.

* Administering competitions and informing you if you have been successful in any competitions or promotions.

* Compiling customer reviews.

* Conducting market research.

* Sending a product to your home address.

* Granting you access to a subscription.

* Dealing with any query or complaint you submit to our customer services team. Only provide sensitive data (such as information about your health, race or religion) if you are happy to consent to our using it to manage your enquiry.

* Sending you push notifications from our apps.

* Ensuring that we are paid the correct amount of commission by our advertising partners to support our journalism.

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?

Consent.

We will only use your personal data for advertising and marketing, personalisation 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.

Legitimate interests.

The legitimate interest pursued by us to analyse 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.

If you wish to contact us by telephone, our number is 0203 615 2990.

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?

We may disclose your personal information to our sister companies: Evening Standard Limited and ESTV Limited as we operate a single group known as ESI Media.

We offer our readers voucher codes in collaboration with Savings United GmbH. We and Savings United are joint controllers of any personal data you provide or that is otherwise collected while you visit www.independent.co.uk/vouchercodes. We must both comply with data protection laws. If you have any questions or concerns about how your data is being used in relation to Voucher Codes, in the first instance please email: contact@savings-united.com.

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 organisations 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 reorganisation 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 recognise 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 using Standard Contractual Clauses, or other safeguards that have been approved by the relevant regulatory body.

Your rights:

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 organisation.

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.

Exercising your rights, asking questions and raising concerns:

In the first instance, please submit your request using our online form available here: Customer Services

You may also lodge a complaint directly with the supervisory authority or our Data Protection Officer using the contact information in the table below.