Effective: 01 JANUARY 2020
- About Us
- Collection of Information
- Our Legal Bases for Using Personal Information
- How We Use and Share Personal Information
- Access & Control of Your Information
- Retention of Personal Information
- Cookies and Similar Technologies
- What Cookies Do We Use and Why?
- Managing Cookies
- Changes to This Policy
- Privacy Tools
- Contact Us
Collection of information
Registration, forums, apps and your dealings with us
We collect information about you when you provide it to us; for example, when you fill out our online forms, subscribe to one of our titles, enter a competition being run on our website, respond to our promotions, comment, engage or participate in website discussion.
Information from devices
Posts, comments and interaction
If you interact, for example by using polls, comments, text messages, video, or email, we may display this content indefinitely in any relevant context, subject to our editorial judgment and your rights as set out in this Policy. This may be anonymized in the case of testimonials or customer service conversations.
If you take part in any reader or listener forums, or send us letters for publication, then you may be identifiable to others publicly and your comments attributed to you.
Public information and posts
Any information about yourself or others that you post on our social media pages, on platforms like Twitter, Facebook and other chat rooms, blogs and forums, will be viewed by other people (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this may be collected and used by third parties.
When you visit our website, advertising networks and other intermediaries select and then display ads on your device.
These companies, generally collect information from your device to help select ads that they believe are more relevant to you. They also use this information to tell advertisers that the ads have been delivered and seen. You can find out more in the Cookies section of this Policy.
Our Legal Bases for Using Personal Information
All organisations need a legal reason to use your personal information. If they don’t have one, they can’t use it. There are a number of legal grounds that enable data processing. Below are the most relevant grounds you should be aware of.
With your consent
There are some activities where we process personal information with your consent. For example, where we want to send you marketing messages by email, we would ask your permission first and you could opt-out at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
To enter into and fulfill a contract
We also process your personal information in order to fulfill a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide a prize to which you are entitled.
For a legitimate interest
We may use your information where there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you or someone else.
We only rely on legitimate interests if the reason for using your information is fair and lawful. Where we want to rely on legitimate interests as a legal basis, we will carry out a balancing test between our legitimate interests and your privacy rights.
Our legitimate interests in processing personal data include:
- to support a free press, including journalistic activities of societal importance;
- to support individual and societal rights to receive information;
- to develop, deliver and maintain relevant and engaging products services and advertising;
- understanding when our audiences engage with us or other organizations;
- to build a clearer understanding of who our audiences are in order to better serve them;
- to carry on the business of a commercial organization; and
- to demonstrate that we provide services and products to agreed industry standards.
To comply with legal obligations
There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This may include publishing information about prize winners, for example.
To provide products and services and improve the experience
How We Use and Share Personal Information
We will use your information to provide you with products and services and to manage our relationship with you, including allowing you to interact, comment, and generally engage with our content.
We may use your information to monitor, improve and protect our products, content, services, and websites, both online and offline. We may also provide you with help and support where we believe it is required. For example, if you have contacted us and provided your contact information, we may contact you with a relevant reply.
To personalize content and ads
We sometimes make assumptions about your interests based on the way you interact with our website and the information we hold about you.
Knowing these preferences also allows us to understand the products, content, and services our customers like, letting us focus our efforts on developing those areas. We may also use this information to make decisions about what ads to show you.
“Do Not Track” browser settings
If you choose to turn on Do Not Track setting in your browser, your browser sends a special signal to websites, analytics companies, ad networks, plug-in providers, and other web services you encounter while browsing to request that they stop tracking your activity. Currently, our website is not designed to respond to “Do Not Track” signals.
To conduct market research and perform analytics
We may use your information to conduct market research to improve the services we offer and to develop new products and services. You will be able to opt-out of receiving market research surveys by following the instructions in the communication.
You may also be asked if you would like to join our audience panels to help us improve our products and services. We value your participation and you will always have the choice to opt-out of these panels.
To gain audience insights
We may provide our partners with information about the effectiveness and reach of advertising campaigns that they have planned or carried out. This information will not identify you directly without your consent.
For example, we may tell advertisers how many customers their ads can reach based on criteria they select (such as “45-year-old women who live in Toronto”) or how many times an ad was viewed.
If you would prefer not to have your information used for audience insights, please email [email protected]
To detect ad blockers
When you visit our sites we may check (using cookies, code, script or other technical means) to see if you have an ad blocker installed on your device or if your internet browser settings allow adverts or not.
If we detect that your device or internet browser is using an ad blocker, we may ask you to “whitelist”, trust or pause blocking adverts while you visit our websites or apps. You can do this easily in your browser settings or within the ad blocker itself. If you continue to use an ad blocker this may have an impact on the content you are able to see on our website.
To allow third-party advertising
In some instances, targeted advertising may be displayed on our website by third parties using our platforms. These third-party ads may collect and use your personal information, which is outside of our control. This targeting may be caused by cookies already in place on your device. More general information on cookies can be found in the Cookies section of this Policy.
To provide co-branded services and features
To disclose your information as permitted by law
Your information may be disclosed where we are permitted by law to do so, for example where we get police requests or regulatory inquiries. We may also disclose your personal information where we are allowed by law to protect or enforce our rights or the rights of others and for the detection and prevention of crimes, such as fraud.
To ensure our services are used appropriately
If you post or send offensive or objectionable content, or otherwise engage in disruptive behavior anywhere on or to our website, we may use your information to stop such behavior. This may involve informing and responding to relevant third parties such as law enforcement agencies about the content and your behavior.
As part of the sale of our business
If we sell part or all of our business, customer information may be one of the transferred business assets. If this happens, your information may be disclosed to our advisers and any prospective purchaser’s advisers and will be passed to the new owners of the business for the purposes set out in this Policy and to ensure continuity of your selected services.
To ensure that our products and services conform to agreed industry standards
We may share your information with auditors for the purposes of verifying that we comply with relevant standards. For example, we may ask third-party auditors to assess our compliance with information security and Privacy by Design best practice. This may require them to access your information in our systems.
Access & Control of Your Information
Withdrawing consent for processing
Where we may rely on your consent to process personal information, you have the right to withdraw that consent at any time. Often, this can be managed through the preference center – such as your consent for us to send you communications. Otherwise, please contact us at [email protected] with details of your request. In some instances, we may still have an alternative legal basis to continue to process that personal information and we will inform you of that. If you do withdraw consent we may not be able to provide the product or service you have requested.
You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.
To exercise any of these rights, please contact us at [email protected] These rights may be restricted by law, for example, we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information.
Retention of Personal Information
We will retain your information for as long as necessary for the uses set out in this Policy, or while there is a legitimate reason for doing so. If you ask us to delete your information before that time, we may not be able to do so due to technical, legal, regulatory or contractual constraints.
Cookies and Similar Technologies
What are Cookies?
A cookie is a text file that is stored on your computer or mobile device by a website’s server and only that server will be able to retrieve or read the contents of that cookie. Each cookie is unique to your web browser. It will contain some anonymous information such as a unique identifier and the site name and some digits and numbers. It allows a website to remember things like your preferences or what’s in your shopping basket.
Our legal bases for cookies and similar technologies
Using information collected from cookies: where we want to use the information that cookies and similar technologies collect, we either need your consent or a legitimate interest. In practice, it will not always be practical to get opt-in consent as doing so with cookie banners and pop-ups would disrupt your use and enjoyment of our sites and content. This is why we usually rely on our legitimate interests to use the data collected by cookies. To do this we conduct an assessment to make sure the purposes for which we use your data are fair and that your privacy rights are considered. We only rely on legitimate interests where your rights do not override our interests in using the data.
For more information about your rights in relation to legitimate interests, please see the section on Access and Control.
What Cookies Do We Use and Why?
Analytics cookies and similar technologies
These collect information about your use of our websites and apps, and enable us to improve the way they work. For example, analytics cookies show us which are the most frequently visited pages on our website, allowing us to provide the most popular news articles further up the page. They help us record how you interact with our website, such as how you navigate around pages and from page to page, identifying improvements we can make to the customer journey. They also help identify any difficulties you have accessing our services, so we can fix any problems. Additionally, these cookies allow us to see overall patterns of usage at an aggregated level.
We may place cookies and similar technologies on behalf of comScore who help us measure the size and quality of our audiences across platforms. You can learn more and control how comScore uses your information here http://www.scorecardresearch.com/preferences.aspx.
Functional/preference cookies and similar technologies
These cookies collect information about your choices and preferences and allow us to remember things like language, and location, so we can show you relevant content to where you are. They allow us to customize the services you have accessed. We also use these cookies to provide you with services such as video content.
Tracking, advertising cookies and similar technologies
We use these types of technologies to provide advertisements that we think may be more relevant to your interests. This can be done by delivering online ads based on your previous web browsing activity, known as “online behavioral advertising” (OBA). Cookies are placed on your browser which will remember the websites you have visited. Ads based on what you have been looking at are then displayed to you when you visit websites which use the same advertising networks.
For example, you may be doing online research to buy a book, and read several articles about relevant books on various websites. As you browse those sites a cookie from an advertising network would be placed in your browser. It would remember that you had visited several websites related to reading. Then, when you visited another website in the same advertising network, the website could show you an ad related to books and or reading.
To help us deliver relevant advertising using cookies, we use Google Double Click. You can find out more about Google Double Click here.
We may also use the Google Analytics tool to track overall browsing patterns on the website. For instance, it helps us identify the most popular pages on the website, find out which links are being clicked on, and to give us broad demographics about from where users are accessing the site. We cannot personally identify users with these cookies.
The five Google Analytics cookies are called utma, utmb, utmc, utmv and utmz. They track how often the website is visited, when you enter and leave the site, and which site you visited that lead you to our website. utmz also tracks any keywords you entered into a search engine that lead you to our website, if appropriate.
Web beacons and tracking pixels
These are bits of data that count the number of users who access a website or webpage and can also allow us to see if a cookie has been activated. Web beacons used on web pages or in emails allow us to see how successful an article has been, or whether an email message was successfully delivered and read in a marketing campaign. Web beacons are also used to verify any clicks through to links or advertisements contained in emails. We may use this information to help us identify which emails are more interesting to you and to inform advertisers how many customers have clicked on their ads (the information shared with advertisers is aggregated and does not identify you individually).
We may, in certain situations, use Adobe Flash Player to deliver special content, such as video clips or animation. To improve your user experience, Local Shared Objects (commonly known as Flash cookies) are used to provide functions such as remembering your settings and preferences. Flash cookies are stored on your device, but they are managed through an interface different from the one provided by your web browser.
Tracking URLs are a special web link that allows us to measure when a link is clicked on. They are used to help us measure the effectiveness of campaigns and advertising and the popularity of articles that are read.
We may collect and analyses a device’s browser information to help identify that device, present content correctly, conduct analytics and help prevent and detect fraud.
If you access our services from a mobile device
We may collect a unique device identifier assigned to that device, geo-location data, and other transactional information for that device. We may also use the unique identifier to validate free trials, for example.
Protect our website
Cookies and similar technologies help us identify and prevent threats to our website. They are necessary to protect your information and our business from outside threats.
Allow you to access our services
Cookies and similar technologies permit your connection to our website: our servers receive and record information about your computer, device, and browser, including potentially your IP address, browser type, other software or hardware information, and your geographic location.
Assess usage of services
We use information about your usage of our website, such as pages you have visited, content you have viewed, search queries you have run, and advertisements you have seen or interacted with to assess how our services are used.
Provide eCommerce functionality
Cookies and similar technologies help us provide functionality that you need to navigate our sites, select products and services and purchase them.
Provide relevant content
The content on our website and in our communications with you may be adjusted depending on what we know about the content, products and services that you may like. This means we can highlight content and articles that we believe will be of interest to you. We provide personalization by using cookies, IP addresses, web beacons, URL tracking and mobile app settings.
Sell third-party advertising
We use third-party advertising companies to serve ads when you visit our Web site. These companies may use aggregated information (not including your name, address, email address or telephone number) about your visits to this and other Web sites in order to provide advertisements about goods and services of interest to you. If you would like more information about this practice and to know your choices about not having this information used by these companies, please see: http://www.networkadvertising.org/managing/opt_out.asp
To learn more about controlling cookies and similar technologies, please see the section below on Managing Cookies.
Where other partners are placing cookies and similar technologies for their own purposes, they are called data controllers and will use your information for their own purposes.
In the future, we plan to release improved controls to allow you to choose which partners can collect and use your information.
Most modern browsers are set to accept cookies by default, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser.
Controlling OBA cookies
In addition to being able to control cookies by changing the settings in your browser on your computer, or in your mobile device’s settings, you can also control which companies can set cookies and similar technologies on your devices, by visiting the following links (you’ll need to turn any cookie or ad blockers off for the control pages to show which companies you can opt-out of):
- Internet Advertising Bureau (IAB) Your Online Choices website provides more information about controlling cookies. It also provides an easy way to opt-out of behavioral advertising from each (or all) of the networks represented by the European Interactive Digital Advertising Alliance http://www.youronlinechoices.com/uk/your-ad-choices.
- The Network Advertising Initiative (NAI)control page allows you to control behavioral advertising from each of the ad networks represented by the NAI.
- The Digital Advertising Alliance’s self-regulatory program for online behavioral advertising control page allows you to control behavioral advertising from the ad networks it represents.
- The News Connect website provides more information and an easy way to opt-out.
Importantly, these ad networks set cookies to remember that you have chosen to opt-out. If you clear your cache the opt-outs will not be applied and you would need to opt-out again.
Controlling Flash cookies
You can manage the use of Flash technologies with the Flash management tools available at Adobe’s website, at http://www.adobe.com/devnet/flashplayer/articles/privacy.html.
Controlling web beacons
You can prevent web beacons from tracking your activity, although you won’t be able to decline receiving them in emails. For information about managing your cookie options, please visit http://www.allaboutcookies.org/.
Please note that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
What to do if you don’t want cookies to be set
Some people find the idea of a website storing information on their computer or mobile device a bit intrusive, particularly when this information is stored and used by a third party without them knowing. Although this is generally quite harmless you may not, for example, want to see advertising that has been targeted to your interests. If you prefer, it is possible to block some or all cookies, or even to delete cookies that have already been set; but you need to be aware that by blocking any or all cookies, you may not have access to certain features, content, or personalization available on our website.
Microsoft Internet Explorer 6.0, 7.0, 8.0
Click on ‘Tools’ at the top of your browser window and select ‘Internet Options’
In the options window navigate to the ‘Privacy’ tab
To enable cookies: Set the slider to ‘Medium’ or below
To disable cookies: Move the slider to the top to block all cookies
Note there are various levels of cookie enablement and disablement in Explorer. For more information on other cookie settings offered in Internet Explorer, refer to the following page from Microsoft: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
Click the wrench icon on the browser toolbar
Click ‘Show advanced settings’
In the “Privacy” section, click the ‘Content settings’ button
To enable cookies in the “Cookies” section, pick ‘Allow local data to be set’, this will enable both first-party and third-party cookies. To allow only first-party cookies pick ‘Block all third-party cookies without exception’
To disable cookies, in the “Cookies” section, pick ‘Block sites from setting any data’
Note there are various levels of cookie enablement and disablement in Chrome. For more information on other cookie settings offered in Chrome, refer to the following page from Google: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Click on ‘Tools’ at the browser menu and select ‘Options’
Select the Privacy panel
To enable cookies: Check ‘Accept cookies for sites’
To disable cookies: Uncheck ‘Accept cookies for sites’
Note there are various levels of cookie enablement and disablement in Firefox. For more information, refer to the following page from Mozilla: http://support.mozilla.org/en-US/kb/Enabling%20and%20disabling%20cookies
Click on ‘Setting’ at the browser menu and select ‘Settings’
Select ‘Quick Preferences’
To enable cookies: check “Enable Cookies”
To disable cookies: uncheck “Enable Cookies”
Note there are various levels of cookie enablement and disablement in Opera. For more information on other cookie settings offered in Opera, refer to the following page from Opera Software: http://www.opera.com/browser/tutorials/security/privacy/
Safari on OSX
Click on ‘Safari’ at the menu bar and select the ‘Preferences’ option
Click on ‘Security’
To enable cookies: In the ‘Accept cookies’ section select ‘Only from site you navigate to’
To disable cookies: In the ‘Accept cookies’ section select ‘Never’
Note there are various levels of cookie enablement and disablement in Safari. For more information on other cookie settings offered in Safari, refer to the following page from Apple: http://docs.info.apple.com/article.html?path=Safari/3.0/en/9277.html
All other browsers
Please look for a “help” function in the browser or contact the browser provider.
Changes to This Policy
In addition to any general data protection inquiries you may have, you can use these details to contact our Data Protection Officer.
By email: [email protected]