ASSOCIATED NEWSPAPERS LIMITED
Privacy & Cookies Policy (the 'Policy') Last Updated: 10 December 2019 ou can control online behavioural advertising cookies on this website via your Cookie Settings. Further details on this can be found under "Managing Cookies" in Section 11 below. What this Policy is for? This Policy explains how we protect and handle any information you provide to us, including via our websites, our apps, social media pages/accounts, email, telephone and in person. It also covers any information we receive from third parties and 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. Who we are dmg media is an international multichannel media company which is home to some of the UK's most popular brands, including the Daily Mail, The Mail on Sunday, MailOnline, Metro, This Is Money, You Magazine, MyMail, MailPlus, Mail+Breifings, MailShop, MailWineClub, MailTravel and MailFinance. These brands are all trading styles of Associated Newspapers Ltd., which is the controller of your personal data for the purposes of data protection law. If you are a MyMail member and have linked your account with your NectarAccount, Associated Newspapers Ltd. and Nectar Loyalty Ltd. ('Nectar') will each be data controllers of your personal data. Associated Newspapers Ltd will handle your personal data in accordance with this Policy and Nectar will handle your data in accordance with Nectar's Privacy Policy and Cookie Policy. If you engage with certain online bargains, discounts, last-minute vouchers and/or similar promotional offers (“Offers”) made available on our websites, or make use of the DailyMail Extras extension for desktop web browsers (“Extension”), we will process your data as joint controllers with Global Savings Group Ltd (“GSG”) and its affiliate CupoNation GmbH, who assist GSG as a marketing partner. GSG will handle your data in accordance with its Privacy Policy and CupoNation GmbH will handle your data in accordance with its with its Privacy Policy and Cookie Policy.1. What kinds of information do we collect:
- Information you've provided to us:
- Information from your device:
- Information collected by the Extension
2. 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 providing you with access to your digital subscription or to provide a prize to which you have won. 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. Legal Obligation: There may be situations where we need to use your information to comply with legal and regulatory obligations or defend claims. This includes publishing information about competition winners. Legitimate Interest: 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. Examples of our legitimate interests processing activities include:- supporting a free press and individual and societal rights to receive information;
- developing, delivering and maintaining relevant and engaging products services and advertising; and
- understanding who our audiences are in order to better serve them.
3. How we may use your information
- Journalism
- Comment Moderation
- Metro.co.uk’s use of Spot.Im’s comment product and moderation services
- Delivering services
- Personalisation/identifying your interests/audience segmentation
4. How we may share your information
Sharing with third-party partners Vendors: When you purchase goods or services from us, we partner with specialist companies to fulfil your order and provide certain customer services. This includes vendors on MailShop who you may have bought something from and specialist companies who assist us in obtaining ratings and reviews of product(s) and/or service(s). We usually remain the data controller of your information and the other companies only process data under our instructions and cannot use the information for their own purposes. If one of our third-party partners acts as data controller of your personal data (whether or not as a data controller in common with us) we will let you know before you register for the service. Legal basis for processing this data: Contract Service Providers: We may pass your information to our processors – companies that we use to provide services on our behalf, for example for delivery services and prize fulfilment companies. These processors can only use your information in accordance with our instructions and for no other purpose. Legal basis for processing this data: Contract, Consent, Legitimate Interest 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. We'll let you know the precise arrangement at the time you provide your personal information. Legal basis for processing this data: Consent, Legitimate Interest Cobranded Products / Affiliate Marketing: We regularly partner with industry affiliates to bring you special deals on products and packages you may find of interest. These include travel providers on MailTravel and financial service providers on MailFinance or This Is Money. 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. If you decide to book a holiday with an affiliate, use their advisory services or set up an account, or purchase a financial product, these affiliates will be data controllers of the information you have provided them in order to administer your relationship with them and will handle your information in accordance with their own privacy policies. Legal basis for processing this data: Legitimate Interest Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our websites and apps. For example, we share data with Google to prevent certain website functions from being abused. Where this happens your data will be processed in accordance with Google's Privacy Policy. Legal basis for processing this data: Consent Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our customers' use of our websites and apps to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers. 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. OBA Partners: Third parties collect and use information obtained during your browsing activities in order to deliver tailored advertisements to you. These parties listed in our Cookies Settings [AA1] tool where we provide you with their details and the ability to opt out of their use. We have no control over the use of your information by these third parties once it has been collected from our sites. Legal basis for processing this data: Consent Marketing personalisation: We may match your data with data held by CACI and Acxiom, to add extra lifestyle and demographic insight information to your account with us which we then use to make our marketing more relevant to you (subject to your communication preferences and our internal policies and procedures). 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 our joint controllers, or adjusting your account settings. For more information on these partners and the data it provides, and to opt out of their programmes directly, please visit them at CACI and Acxiom. Legal basis for processing this data: Consent, Legitimate Interest Facebook insights data: Facebook Ireland Ltd (“Facebook”) provides us with statistics and insights (“Page Insights”) that help us understand the use of our Facebook Fan Pages (e.g. Daily Mail, Daily Mail Celebrities, Daily Mail Australia, Daily Mail Sport, Daily Mail Animals, Daily Mail Videos, etc.). When you visit or interact with one of our Facebook Fan Pages, we will process your personal data as Joint Controllers with Facebook. Facebook is primarily responsible for the data processing when you visit one of our Fan Pages. However, we use Page Insights and information you provide via your Facebook profile to define our audiences, customise advertisements and create Fan Pages to match the interests of our visitors. For further information from Facebook about: · Page Insights and how to exercise your rights, please see here; · the determination of the responsibilities within this joint controller relationship please see here; · the placement of cookies by Facebook when visiting a Facebook Fan Page, please see here; and · protecting your privacy at Facebook, please see here. Legal basis for processing this data: Legitimate Interest Social Media Plugins: Some of our websites use social media plugins to help you share content more easily with your friends.Social Media Plugin | Privacy policy |
---|---|
Facebook Share Button Facebook Messenger Share Button Facebook Like Button |
https://www.facebook.com/policy.php |
Twitter Share Button Twitter Follow Button |
https://twitter.com/en/privacy |
Pinterest Share Button Pinterest Follow Button |
https://policy.pinterest.com/en-gb/privacy-policy |
Flipboard Share Button Flipboard Follow Button |
https://about.flipboard.com/privacy/ |
Instagram Follow Button | https://help.instagram.com/519522125107875 |
Snapchat Follow Button | https://www.snap.com/en-GB/privacy/privacy-policy |
5. Details of transfers to third countries and safeguards
Any organisation who has access to your information in the course of providing services on our behalf will be governed by contractual restrictions and/or technical limitations to make sure they protect your information and comply with applicable data protection legislation. Where these organisations are based outside of the EEA in a jurisdiction that has not been deemed adequate by the EU, we enter into EU approved model clauses with them to ensure appropriate safeguards are in place.6. How our brands work together
The Daily Mail, The Mail on Sunday, MailOnline, Metro, This Is Money, You Magazine, MyMail, MailPlus, MailShop, MailTravel and MailFinance share infrastructure, systems and technology and all fall under the data control of Associated Newspapers Ltd. These brands work together to understand how our users interact with our products and services, and to share insights to improve our products and services.7. How can you exercise your rights under the GDPR
If you are contacting us, or our joint controllers, 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.- Access: If you wish to exercise your right to access a free copy of your data, you can contact us, or our joint controllers, at the contact details provided below at Section 12.
- Deletion: To ask us to delete your personal data, please contact us, or our joint controllers, 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 directly by accessing your account settings.
- Revoke consent for direct marketing: If you wish to object to the processing of your data for direct marketing you can opt-out by updating your settings or clicking on the 'unsubscribe' link in any marketing email or newsletter you receive from us.
- Opt-out of online behavioural advertising: You are able to control whether we and our partners may use your information for online behavioural advertising related purposes when you visit our websites via our ‘Consent Management Platform that appears when you first visit our sites, or by clicking on the Cookie Settings link in this Policy.
- Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalisation 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 contact us, or our joint controllers, at the contact details provided below stating the nature of and reasons for such objection.
- Complain: You also have the right to lodge a complaint about us with our supervisory authority, the Information Commissioner's Office.
- Browser pop-up notification opt-out
- Click the 3 dots at the top right
- Select settings > advanced > privacy and security > content settings > notifications.
- Here you'll see the websites allowed and those which are blocked. Just remove all the websites that are in the “allowed” category that you don't want notifications from.
- Choose Safari > Preferences, click Websites, then click Notifications.
- Find the website in the list, then select Deny.
- Click the menu button and select Options.
- Select the Privacy & Security panel and go down to the Permissions section.
- Click the Settings… button next to Notifications.
- Select the website.
- Click Remove Website.
- Click the three dots button in the top-right of the browser window.
- Click "Settings".
- Click "View advanced settings".
- Under "Notifications", click "Manage"
8. California Consumer Privacy Act (“CCPA”) – this section is applicable from 1 January 2020
This section of the Policy applies solely to visitors, users, and others who reside in the State of California and describes your CCPA rights and explains how you can exercise those rights. Under the CCPA you have the right to: • be informed about the categories and the specific personal information that we may collect, and the purposes for collecting that personal information. - This information is provided in this Policy; • request a copy of the personal information we have collected about you; - upon receipt of a valid and verifiable request from you, we will disclose to you both the categories and specific pieces of personal information we have collected about you, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting that personal information, the categories of third parties which whom we share that information; - you have a right to receive the above-requested twice per year - if we provide the information electronically, it will be in a in a portable and, to the extent technically feasible, in a readily useable format that allows you to transmit the information to another entity without hindrance from us. • request that we delete any personal information that we have collected from you unless retention of that information is permitted under applicable law • opt-out of the sale of your personal information - You can opt-out of the sale of your personal information by opening our California Privacy Settings (applicable from 1 January 2020) tool and clicking on the “Do Not Sell my Info” button. This will opt-you out of cookie placement and the collection of your data by online advertising service providers. Exercising Access and Deletion Rights • To make such a request, please send an email to dataprotection@dmgmedia.com with “CCPA Request” in the subject line. • Explicit Notice We and our advertising partners collect personal information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site or use our app. We, and our partners, use this information to tailor and deliver ads to you on our site or app, or to help tailor ads to you when you visit others' sites or use others' apps. To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties. If you do not wish for us or our partners to sell your personal information to third parties for advertising purposes, select the applicable control from the “Do Not Sell My Info” link provided. Note that although we will not sell your personal information after you click that button, we will continue to share some personal information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud. If you access this site or app from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the data collected when you use those devices or browsers. If you use different browsers, devices or platforms, you will need to opt out on each browser, device or platform. Additionally, although clicking the “Do Not Sell My Info” link will opt you out of the sale of your personal information for advertising purposes, it will not opt you out of the use of previously collected and sold personal information (except for personal information sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising. If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out. Alternatively, you can make your request through the technical support option on our contact us page here:https://www.dailymail.co.uk/home/contactus/index.html9. 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.10. Children & young people
Our websites, apps and other products and services are not aimed at children. We do not intentionally target, or otherwise process information from individuals in the European Economic Area, the United Kingdom, and Switzerland who are under the age of 16. We do not create interest segments specifically designed for the purpose of online behavioural advertising to children who are under the age of 16. If you live in the European Economic Area, the United Kingdom, or Switzerland, you must be at least 16 years of age to consent to online behavioural advertising via your Privacy Settings. If you are a parent or guardian of a child under 16, please contact us, or our joint controllers, 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.11. Cookies
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 recognise 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 tocookies to:
- Flash cookies: In certain situation 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.
- 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; and
- 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'.
- Mobile Devices: When using a mobile device, you can opt-out of receiving online behavioural 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 behavioural advertising (referred to as an 'Advertising ID') in the Settings on your Apple or Android device.
- OBA Cookies: If you are primarily concerned about third party cookies generated by advertisers, you can turn these off by going to Your Online Choices.
- 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.
- You can also visit the trade body representing these advertising platforms where you can control your third-party online advertising preferences by going to the Network Advertising Initiative.
- 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:
12. 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.13. 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: dataprotection@dmgmedia.co.uk Alternatively, you can write to us at: Legal Department – Data Protection & Privacy Associated Newspapers LimitedNorthcliffe House
2 Derry Street
London, W8 5TT
U.K. You can also contact our Data Protection Officer at: DMPrivacy@shoosmiths.co.uk Alternatively, you can write to them at: Shoosmiths LLP
F.A.O Data Protection Officer - Associated Newspapers Ltd
Platform, New Station Street,
Leeds, LS1 4JB
U.K.